The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading
The Cyprus government has introduced radical tax reforms that aim to attract foreign direct investments and non-domiciled individuals, simplify levies for properties, return tax-collection to local municipalities and encourage tax-breaks for direct injections where local companies are strained for cash-flow, reports the Financial Mirror. Finance Minister Haris Georghiades said that… – Continue reading
On 1 July 2015, the President of Cyprus announced a number of tax reforms. The tax reforms will aim in modernising the taxation framework of Cyprus and making it more fair and more competitive, while limiting the taxation burden and offering incentives for growth. The announcement was made while Addressing… – Continue reading
Florida governor releases 33 years of tax returns. Jeb Bush made $29 million in the first seven years after he left public office, dramatically increasing his wealth during a recession, a financial crisis and the Obama presidency he has criticized. Bush’s tax returns, released Tuesday, show how the former Florida… – Continue reading
The Full Court of the Federal Court has recently removed previous doubts concerning whether Part IVA could be applied to a scheme involving the formation of a tax consolidated group. In the case that was before the Full Court, a company (Subco) joined a tax consolidated group and as a… – Continue reading
It is that time of the year when you get your Form 16 from your employer and gear up to file income tax returns (ITR) for the financial year gone by. This year the government has come out with a new ITR form. Also there is more to disclose while… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
Introduction The UK Finance Act 2015 received royal assent on March 26 2015. This included final legislation for the introduction of a capital gains tax charge on non-residents who dispose of UK residential property. The new charge applies to such disposals made on or after April 6 2015. This update… – Continue reading
The General Anti-Avoidance Rules (GAAR) are of no use to India, and may work against the country by hurting foreign inflows is the word coming in from Vishnu Lutchmeenaraidoo, the Finance Minister of Mauritius, reports Money Control. He told CNBC-TV18 that lower taxation is the need of the hour for… – Continue reading
NEW DELHI: Mauritius has offered to put in place stringent conditions for investors seeking benefits under its tax treaty with India to weed out post-box operations, addressing a key concern of New Delhi that has been attempting to amend the agreement for years. “We don’t want investors to open shell… – Continue reading
Accounting and legal professions in Ireland oppose major strands of business tax plan Key strands of the Organisation for Economic Co-operation and Development plan (OECD) to overhaul global business tax rules have run into resistance within the accounting and legal professions in Ireland. A submission this week to the Paris-based… – Continue reading
With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
Britain’s taxing question is whether to maximise revenues or face more austerity. Given the scale of state spending that’s the stark choice facing chancellor George Osborne if he wants to balance the books in this parliament, says James Sproule We are once again considering the tax options facing the chancellor… – Continue reading
A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading
Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading
New Delhi/Mumbai: India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinational companies (MNCs) on pacts to avert tax rows, people familiar with the matter… – Continue reading
MUMBAI: Two associations representing foreign portfolio investors are seeking to join the battle over minimum alternate tax in the Supreme Court, although analysts are unclear if entities without a tax treaty will benefit. Investment Association, based in London, and Hong Kong-based Asia Securities Industry & Financial Markets Association (ASIFMA) plan… – Continue reading
The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading
Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading
Capital gains tax charges from 6 April 2015 The scope of capital gains tax (CGT) has been extended and now applies to gains arising on the sale of UK residential property by non-UK tax residents (non-residents). Only gains arising after 5 April 2015 are subject to the new charge as… – Continue reading
The proposed common corporate tax base for companies operating in the European Union is intended to reduce tax avoidance. The European Commission is planning to crack down on international tax avoidance by proposing that companies operating in the European Union follow a single set of rules to calculate taxable profits…. – Continue reading
Peter Scully writes: From 6 April 2015 there will no longer be tax advantages for non-UK residents who invest in the UK residential property market. These changes have seen Capital Gains Tax (CGT) exemption being removed along with restricted access to Private Residence Relief (PRR) as well as the potential… – Continue reading
Non-Resident Indians (NRI) constitutes a significant portion of buyer percentage when it comes to real estate transactions in India. Irrespective of constituting a considerable portion, they still face a lot of hassles in the process of taxation when buying or selling properties. Rajan Pillay representing his client who is an… – Continue reading
Egyptian tax on shares sold by non-residents In 2014, the Egyptian Income Tax law was changed to introduce a 10% Egyptian tax charge on the net gain realised on a disposal of shares in an Egyptian company. This tax charge is intended to apply to non-resident as well as resident… – Continue reading
By stopping bogus claims of residency, his idea would force foreigners to pay capital gains tax when they sell a home in Canada OTTAWA — Inspired by the legendary FBI ploy to nab a notorious gangster, a B.C. immigration lawyer suggests the Canadian tax system be used to discourage the… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
The Green Party is congratulating the Government for beginning to see sense on a capital gains tax, but is warning that limiting it to properties sold within two years of purchase doesn’t go far enough. “This is a welcome U-turn from the Government. Only last week they were saying that… – Continue reading
Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading
The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading
The Chinese government has been paying close attention recently to the effects of offshore entities having ownership or control of Chinese companies or assets. Following the release of the draft Foreign Investment Law in January 2015, the State Administration of Taxation (SAT) issued a Bulletin on the tax treatment of… – Continue reading
I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading
On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading
After finding them guilty of manipulation in the stock market for making illegal gains, Sebi has restrained the 178 entities, including Pine Animation, from accessing the securities market. In a fresh clampdown on misuse of stock market platform for suspected money laundering activity, Sebi today banned Pine Animation and 177… – Continue reading
Analysts at the accountancy firm found that the UK system was even more intricate than the equivalent structure in France The British property tax system is now the most “complex” in the world, endangering London’s reputation as an investment haven, according to new analysis from accountancy firm PwC. Research showed… – Continue reading
Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading
New Delhi: Market regulator Securities and Exchange Board of India (Sebi) has asked bourses to take immediate action against entities involved in misuse of stock exchange system for tax evasion, Parliament was told Friday. Preliminary enquiries conducted by the regulator in the recent past, inter alia, indicate that certain persons/companies… – Continue reading
Minister of Revenue, Todd McClay today welcomed the release of an officials’ issues paper that seeks feedback on suggestions for helping to ensure that non-resident investors pay an appropriate amount of tax. The focus of the issues paper is the current non-resident withholding tax rules on interest earned in New… – Continue reading
Exchange Traded Funds (ETFs) have gained huge popularity in recent times with Irish investors; however, there has been much complexity and uncertainty in relation to their tax treatment. The concept of an ETF is not specifically provided for in Irish tax legislation. It depends on the legal form and characteristics… – Continue reading
PART I – CAPITAL GAINS TAX If you are thinking of doing a Will, or you are the executor of a deceased estate, it is important to consider what taxes and duties may be payable by the estate or the beneficiaries when the time comes for an executor to deal… – Continue reading
NEW DELHI: Ahead of Prime Minister Narendra Modi’s visit to South Korea this month, the Cabinet today approved revising the double tax avoidance pact with Seoul to provide tax stability and facilitate flow of investment and technology between the countries. The Cabinet headed by the Prime Minister gave its approval… – Continue reading
UK funds invested in India could face demands for tax from which they thought they were exempt. Minimum alternate tax (MAT), a tax on the book profit of a company, has been in existence in India in its current form since 2001 and is levied at 18.5 per cent. Because… – Continue reading
Bipartisan legislation has been introduced into the House of Representatives to amend the Foreign Investment in Real Property Tax Act (FIRPTA) of 1980 that requires foreign investors to pay taxes on capital gains when selling commercial properties or real estate securities in the United States. To encourage foreign investment in… – Continue reading
A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading
The IRS, the most powerful and least accountable agency of the federal government, is an admitted criminal enterprise. To deal with this, Republican candidates for president are placing tax reform at the top of their agendas. You will have to guess why the Democrats seem not to care. Sen. Ted… – Continue reading
The parties to licenses of technology should consider tax issues with such licenses. The following is a summary of some of the tax implications that may arise with regard to technology licenses. Withholding Taxes. Where a license crosses an international border, withholding taxes may apply to any royalties payable. Under… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading
Morgan Stanley veteran and former managing director Sridhar Sivaram told NDTV that the government’s decision to levy the contentious minimum alternative tax (MAT) retrospectively on foreign institutional investors (FII) for capital gains made during previous years, poses a hindrance to foreign fund flow into the country. “It’s very tough to… – Continue reading
