Negotiations took place, on 2 July 2015, at the Ministry of Finance of the Republic of Cyprus, concluding a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income, when it expires. The agreed protocol, when… – Continue reading
A new tax test on the sale of residential properties is coming – the bright line test. If you buy and then sell a residential property within two years new taxation rules may apply to the gain (or loss) that you make. Existing tax law provides for tax on sales… – Continue reading
On April 1, 2015, Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since December 8, 1998. At the time the original DTA was concluded, dividends arising in South Africa were not subjected to South… – Continue reading
Suggests ending STT on equity derivatives, stamp duty on index ones; also for rupee’s internationalisation, other changes A government-appointed panel has recommended abolition of the securities transaction tax (STT) in equity derivatives. The standing council on international competitiveness of the Indian financial sector also suggested doing away with the stamp… – Continue reading
Republican presidential candidate Jeb Bush has outlined a tax reform plan that would raise taxes on some private equity managers and other investors. In doing so, the plan would fulfill a goal often called for by liberal tax analysts and, more recently, fellow Republican candidate Donald Trump. Bush’s tax plan,… – Continue reading
On September 8, 2015 the Cypriot Ministry of Finance published an announcement titled: “Conclusion of a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income between the Republic of Cyprus and the Government of Ukraine… – Continue reading
LAHORE (Dunya News) – All Pakisan Traders Union on Tuesday warned of marching towards Islamabad if the government did not withdraw withholding tax. Addressing a press conference at Lahore Press Club, Naeem Mir, the General Secretary of All Pakistan Traders Union, said that a protest has been scheduled on September… – Continue reading
Investors could be hit hard if they are taxed on the capital gains earned from the sale of holdings in FPIs Today, a stable, predictable tax and regulatory regime is a sine qua non for creating a conducive climate for foreign portfolio investors (FPI). Investors wishing to invest in India… – Continue reading
By accepting the recommendations of the AP Shah panel on the issue of retrospective tax demand on FIIs, the Narendra Modi government has added one more item to the long list of its U-turns. And at the face of it, this one definitely is a wise one, though the question… – Continue reading
One of Ireland’s richest persons, John P. McManus, seeks $5.2 million from the U.S. government after it was wrongfully withheld from his $17.4 million gambling winnings to cover taxes. In a complaint filed Monday in the U.S. Court of Federal Claims, McManus accuses the withholding agent of erroneously withholding the… – Continue reading
New Delhi: Expressing concerns over the outflow of funds from developing countries, including India, through money laundering and other ways, Minister of State for Finance Jayant Sinha today said as much as $300-600 billion moves out through such channels. “Illicit financial flows means the money that actually is black money,… – Continue reading
Malta’s tax legislation provides for a number of benefits which can be derived by companies and their shareholders. The tax rules can lead to a tax burden in Malta which is significantly reduced or completely eliminated in certain cases, and the following are some of the key tax benefits which… – Continue reading
For the past few years, Canadians have been taking advantage of our dollar being worth about the same as the U.S. dollar. From buying up real estate to cross-border shopping, being on par with the U.S. dollar has had its advantages. However, in the last few months, economic factors have… – Continue reading
In addition to its main function to eliminate double taxation, a tax treaty is also intended to promote foreign direct investment (FDI). Investors normally consider the treaty networks of a targeted investment country in deciding their investments. The more extensive the treaty networks, the more attractive for the investors. Extensive… – Continue reading
United Kingdom | August 31 2015 Last month, the UK government announced sweeping changes to the taxation of “resident non doms,” a classification of individuals who receive favorable tax treatment from the UK government. The UK tax obligations of an individual depend in large part on the individual’s “domicile” under… – Continue reading
Rejecting “treaty shopping” claims, India’s High Court of Punjab and Haryana has ruled that India should not tax capital gains from the sale by Mauritian entities of shares held in an Indian company if they are proven resident in Mauritius. The ruling was given in Serco BPO Private Limited v…. – Continue reading
It’s a decision that could spell relief for many Mauritius based investors. This week the Punjab & Haryana High Court has re-iterated that a Mauritian tax residency certificate is sufficient to avail treaty benefits. Senior advocate Porus Kaka tells CNBC TV18’s Menaka Doshi that this re-iteration is important given the… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
Personal incomOn 23 July, the Belgian federal government agreed the budget review for 2015 and 2016 and the implementation of the long awaited tax-shift plan. The aim of the tax shift is to reduce the Belgian tax burden on labour, improve the competitiveness of Belgian companies and create new jobs…. – Continue reading
In the overview of tax treaties as published on the website of the Irish Revenue, the Irish Revenue has published a statement announcing that the Convention between the Government of Ireland and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… – Continue reading
The Maltese climate, culture, history and lifestyle make Malta an attractive place to live in. The fact that this is coupled with a beneficial tax system for people taking up residence in Malta makes Malta an even more desirable location. Introduction to Malta Situated in the middle of the Mediterranean… – Continue reading
The Income Tax Act (ITA) contains many anti-avoidance rules forbidding taxpayers from misusing the provisions of the ITA to achieve tax benefits contrary to Canadian tax policy. The 2015 Federal Budget has proposed changes1 to one of these anti-avoidance rules, which may significantly impact the ability of business owners to… – Continue reading
The Revenue Department may soon come out with a circular on providing relief to FIIs from the minimum alternate tax (MAT) with retrospective effect. “Government is likely to soon issue circular giving relief to FIIs on MAT prior to April 1,” a senior Finance Ministry official said. The government-appointed AP… – Continue reading
The Cyprus government recently announced a number of tax incentives aimed at encouraging economic activity and attracting inward direct investment. At the same time it submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
Dubai – Cyprus’ recently revised taxation framework make sit the only citizenship-by-investment program in Europe to offer non-domiciled investors tax free profits. Will this new tax regime and business incentives attract more foreign direct investment (FDI) into the country? Henley & Partners, the global leaders in residence and citizenship planning… – Continue reading
MUMBAI: As it steps up its crackdown on tax evasion and laundering of black money through stock markets, regulator Sebi has busted an ‘innovative’ scheme wherein HNIs were incurring ‘bogus losses’ to offset tax liabilities. The probe, which has resulted in an interim ban on 59 entities, including HNIs and… – Continue reading
A round of capital flight is taking place in China, with many of the country’s wealthy rushing to send their assets abroad to dodge an imminent introduction of inheritance tax. A significant example is the recent purchase of a luxury house in Hong Kong by Alibaba founder Jack Ma for… – Continue reading
LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading
In what could turn out to be a major relief for foreign investors, an expert committee has recommended that there was no case for imposing the controversial minimum alternate tax (MAT) on foreign institutional investors (FIIs) with retrospective effect. The A.P. Shah Committee, appointed to examine the issue of levying… – Continue reading
Improvement of the e-management system for value added tax The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on 16 July 2015. The law in its main part came into… – Continue reading
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading
Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading
The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading
With the objective of long-term sustenance of wealth created both inside as well as outside India and continuous revenue generation, high net-worth individuals (HNIs) in India have decrypted and adopted innovative methods for asset protection and estate planning. The latest addition to the existing gamut of methods are offshore investments… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
The Bombay Stock Exchange (BSE) is putting in place a series of measures to prevent use of its exchange platform by various unscrupulous entities to evade taxes and launder money. These measures include putting additional circuit filters on stocks that are susceptible for price manipulation and reducing the number of… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
MUMBAI: Large foreign portfolio investors (FPIs) have voiced concerns before Indian capital market regulator Sebi about the fate of the Mauritius treaty which the government is renegotiating with the tax haven. Officials of more than 20 offshore asset managers, belonging to top banking groups and fund houses, met Sebi chairman… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading
Accommodation company Airbnb has held a meeting in Dublin, for people in Ireland who may owe tax on income earned by renting rooms and properties through the website. However, Airbnb hosts said there was no tax or legal expert to answer their questions and the meeting did not provide clarity… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
High net worth individuals seen using illiquid stocks in options segment to evade taxes, manipulate markets; order likely soon The Securities and Exchange Board of India (Sebi) is likely to act against several wealthy investors, for alleged manipulation of the stock exchange route for evading taxes. Sources said the market… – Continue reading
Prime Minister Narendra Modi needs to offer much more than just his best intentions to clean up India’s whimsical tax regime to help convince insurers. Companies from Allianz SE to American International Group Inc. are avoiding offering tax-liability coverage in India’s cross-border mergers and acquisitions market because of a relatively… – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
The recommendations of Justice AP Shah-led three-member committee on minimum alternative tax (MAT) has come in for big relief to foreign investors. The 64-page report, exclusively accessed by dna, says a foreign investor is not liable to pay MAT prior to April 1, 2015. The report, however, is silent on… – Continue reading
Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading
