Category: Capital gains

Ireland: Aviation Finance & Leasing 2022

Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading

Canada: “Changing Of The GAAR”: A Background On The General Anti-Avoidance Rule, And Canada’s Attempt To Expand Its Tax Power In The 2022 Budget

The Budget purports to introduce several new financial and taxation regimes, as well as enhance several existing mechanisms. One of the existing taxation mechanisms proposed to be amended is the General Anti-Avoidance Rule (the "GAAR"). The Government initially indicated they would be amending the GAAR in the 2021 Budget. The 2022 Budget now provides some additional detail, though we are still waiting for the actual legislation. ... - Continue reading

How much capital gains tax you pay in Portugal?

Like many countries, Portugal imposes a capital gains tax on the sale of assets. It only applies to gains made on real estate and investments; personal items are not taxable and inheritances are only subject to a limited form of stamp duty. Your exposure will depend on whether you are resident, how you own the asset and, with property, whether it is your main home. ... - Continue reading

Requests for confirmation, tax treaty relief applications and tax sparing applications

IN 2021, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order (RMO) 14-2021 and Revenue Memorandum Circular (RMC) 77-2021, which streamlined the procedure for the availment of benefits under the applicable tax treaty.  ... - Continue reading

Polish Deal introduces new minimum tax for corporations

On 8 September, Poland’s government accepted a new tax bill called the “Polish Deal,” announcing after the public consultation on the bill a significant amendment to include a special anti-avoidance measure referred to as a minimum income tax for corporations. ... - Continue reading

UK: Tax Bites – June 2021

Further extension to UK Common Reporting Standard compliance rules

Regulations have been made to extend the International Tax Compliance Regulations 2015 (SI 2015/878) (the Compliance Regulations). The Compliance Regulations, among other things, require UK financial institutions to report information regarding certain non-UK account holders to HMRC for exchange under international arrangements relating to the Common Reporting Standard (CRS). ... - Continue reading

Ten-year tax incentives granted to special technology zones

The government has granted a comprehensive duty and tax incentives for a period of 10 years to investors operating in the proposed special technology zones (STZs), sources in the Federal Board of Revenue (FBR) said on Monday. The incentives also include immunity from explaining the source of funds to be… – Continue reading

Canada: Don’t Let Your Dream Vacation Home Become A Tax Nightmare

Renting your foreign property may require you to disclose information to the Canada Revenue Agency (the "CRA"). A Foreign Income Verification Statement is required to be filed with the CRA where the adjusted cost base of the property exceeds CDN $100,000.  ... - Continue reading

Ireland Budget 2020 released

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

Bermuda: Chambers Private Wealth 2019: Bermuda (2019)

1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019.  ... - Continue reading

Cyprus: The Cyprus Investment Programme And The Benefits

The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

  • Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
  • The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
... - Continue reading

Hong Kong: A Guide To Tax Regulations In Hong Kong 2019 – 2020

While considering moving a business into a new market, one of the key consideration is that country's tax regime. What are the incentives that would attract foreign investment? Are there any double tax treaties in place? What is the rate for corporate tax? ... - Continue reading

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading

Revised tax treaties usher in a new era in investment, taxation

Policy tweaks  curb evasion,  show  India  can woo investments without  sops Singapore, another major FDI contributor to India, too, enjoyed the same tax sops under a similar treaty with India NEW DELHI: For about a decade-and-a-half, revenue authorities examining foreign investment proposals received by the erstwhile Foreign Investment Promotion Board… – Continue reading

Non-resident capital gains tax on UK commercial property ‘could block overseas investment’ – expert view

The Government’s changes to the tax treatment of overseas investment in UK commercial property will increase revenues in the short term but might prove short-sighted, write Craig Hughes and Russell Dickie There is, as they say, no place like home. However, in recent years, solid and steady capital growth and… – Continue reading

PSX recommends CGT exemption for foreign investors in next fiscal year

—Says exemption to facilitate capital inflow by relaxing account opening, registration process ISLAMABAD: The Pakistan Stock Exchange (PSX) in its proposals for budget 2019-2020 has recommended exemption of capital gain tax (CGT) on disposal of securities by foreign investors. Budget proposals for next fiscal year 2019-20, available with Pakistan Today,… – Continue reading

HMRC targets wealthy families with trusts

Changes to Britain’s centuries-old trust regime are looming as HMRC is concerned that trusts are letting some families pay less inheritance tax than those who do not pay accountants to set up the complex arrangements. To look at if the law should be changed, HMRC has published wide-ranging research of… – Continue reading

Ireland Implements New Exit Tax Regime

Ireland’s 2018 Finance Bill legislates for a new exit tax regime compliant with the EU’s Anti-Tax Avoidance Directive. The exit tax charge was introduced via financial resolution on Budget night, October 9, 2018, and applies to certain events occurring on or after October 10. Finance Bill 2018 formally legislates for… – Continue reading

Walmart-Flipkart Deal: Income Tax Dept Rejects Plea For Capital Gains Exemption

Income Tax department is also inquiring into some alleged suspicious transactions and investment flow into Flipkart Authorities have demanded a valuation report from Flipkart The international taxation division of the I-T department is currently studying the valuation of Indian assets of Flipkart Singapore At the time when ecommerce company Flipkart… – Continue reading

Capital Gain Exemption can be allowed to House Property acquired in Foreign Countries: ITAT [Read Order]

The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled for capital gain exemption under section 54F of the Income Tax Act in respect of the properties acquired outside India. In the instant case, the Revenue approached the Tribunal contending that for granting benefit… – Continue reading