Introduction In July 2015, a number of bills relating to the Cyprus taxation system were approved by the Council of Ministers and subsequently enacted into legislation by the Parliament1. The key highlight of these new bills is the introduction for the very first time of the “non-dom” status for Cyprus… – Continue reading
As of 2019, the Individual Investor Program has received more than 1000 Malta passport applications on behalf of investors from more than 40 different countries. The Malta Individual Investor Programme (MIIP) offers high and ultra-high net worth individuals and families worldwide citizenship in a highly respected EU Member Country. Malta,… – Continue reading
Background Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe. Portugal is increasingly recognised as an international hub with 71 Double Taxation… – Continue reading
The announcement by National Treasury and SARS in 2017 that the tax exemption on South African expatriates is set to change, has resulted in the lifestyle of many South Africans, who are employed by companies abroad, to rapidly change from a South African tax liability point of view. By Claudia… – Continue reading
A top Central Bank official has accused the OECD of trying to “hobble” the competitiveness of The Bahamas’ economic permanent residency regime by including it in an arbitrary “quasi-blacklist”. Charles Littrell, the regulator’s inspector of banks and trust companies, in a speech to a Turks & Caicos financial services conference,… – Continue reading
In general, investment and tax provisions relating to non-resident Indians (NRIs) returning to live in India are fairly generous. However, NRIs must carefully plan their return to India to ensure there are no surprises with respect to managing their overseas income and investments. In this article, we examine some of… – Continue reading
Introduction A person’s status as a tax resident determines the extent to which Canada may tax that person’s income. The test for whether an individual—i.e., a natural person—is a Canadian tax resident turns on the individual’s particular circumstances. Every detail counts. But Canadian courts and the Canada Revenue Agency both… – Continue reading
China’s double tax avoidance agreements (DTAs) can be used to avail lower tax rates while making outbound payments. However, DTA benefits are not automatically applicable to everyone. Foreign invested enterprises and their overseas headquarters must satisfy certain qualifications and go through relevant procedures to obtain the benefits. Beneficial owner assessment… – Continue reading
The Antigua and Barbuda government is willing to amend the necessary laws to ensure that local financial institutions are able to share banking information of dual citizenship holders with the relevant authorities in their original country of birth, if this becomes necessary. Prime Minister Gaston Browne made the disclosure following… – Continue reading
The Organisation for Economic and Social Development named and shamed 22 countries out of over 100 it studied that have either residency or citizenship programmes, for having lax rules that potentially pose high-risk to the integrity of Common Reporting Standard’. Malta, which has long cited the OECD’s endorsement of its… – Continue reading
In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading
How tax residency in China gets determined is among key changes introduced in the recently passed individual income tax (IIT) law. The new law is set to reform IIT in the country, including the tax treatment of foreigners. Beginning January 1, 2019, an individual who resides in China for 183-days… – Continue reading
THE VALLEY, Anguilla — The government of Anguilla is to implement a “Residency by Investment” programme as part of its medium-term agenda. It will allow foreign nationals to acquire permanent residency status in Anguilla by making a financial contribution to the island and after proving to be of good health… – Continue reading
Only just over 3 per cent of houses sold or transferred in the March quarter went to foreigners, Stats NZ data shows. Of the properties which transferred to new ownership in the three months, 3.3 per cent went to people who were not citizens or residents, up from 2.9 per… – Continue reading
When it comes to cryptocurrencies, an area that is often overlooked is that of exchange control, and whether the acquisition or trading in cryptos may (even inadvertently) lead to a transgression under the exchange control regulations. According to Leon Rood, director at Werksmans Attorneys, while the South African Reserve Bank… – Continue reading
PARIS — Tom Wallis was born here and has spent his entire life in France, but it turns out that the 40-year-old entrepreneur from Grenoble owes tens of thousands of dollars in taxes to the United States. Wallis’ mother was French, but he holds U.S. citizenship through his American father…. – Continue reading
On the occasion of the signing of the new double taxation treaty (DTT) between Luxembourg and France on 20 March 2018, the grand duchy’s finance minister, Pierre Gramegna, commented in a government press release that the new DTT is, “…an innovative instrument that will benefit both citizens and business in… – Continue reading
The Indian Central Board of Direct Taxes has issued a statement to defer the filing obligation on surrogate parent entities with regards to country-by-country reporting. Section 286 was inserted into the Income Tax Act 1981 through the 2016 Finance Act to introduce a requirement to furnish a country-by-country report. The… – Continue reading
The Government’s planned legal reforms pave the way for the introduction of “corporate taxation” on a wide range of Bahamian financial services products, it was revealed yesterday. Carl Bethel QC, the Attorney General, confirmed to Tribune Business that legislation intended to address the European Union’s (EU) ‘blacklisting’ concerns was designed… – Continue reading
Those who hold an account (or are a controlling person) with Hong Kong Financial Institutions – both individuals and entities – must prepare to report their tax residency information to the Inland Revenue Department (IRD) by May 2018 for exchange with 75 reportable jurisdictions under the AEOI standard. In September… – Continue reading
Fleets have been reminded that from 6 April company car drivers in Scotland face larger tax increases than those in the rest of the UK, with new income tax rates introduced. The rise has been flagged by leasing and fleet management company Activa Contracts, which has updated its software systems… – Continue reading
Estonia is expected to get a 100-to-one-euro return on investment for its e-Residency program, which lets anybody start a business from afar. It is even planning to launch ‘estcoins,’ its own cryptocurrency. Becoming a ‘digital resident’ of Estonia, Michael M. Richardson says, was “as easy as getting a fishing license… – Continue reading
The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition… – Continue reading
A major new global transparency measure aimed at curbing cross-border tax evasion by requiring countries to share information on the wealth of each other’s nationals could be undermined by the abuse of residency- and citizenship-for-sale schemes. Tax justice campaigners say that some of these schemes are already being marketed as… – Continue reading
The company known for the ‘double Irish’ scheme is moving its subsidiaries’ tax residency. A set of leaked documents from offshore law firm Appleby has revealed that Apple stashed $250 billion in Jersey, a tiny island off the coast of France known for being a tax haven. The tech titan… – Continue reading
Summary: With effect from 1 January 2017, a number of amendments to Russian law have come into force which will affect aircraft leasing arrangements for lessors and financiers that have aircraft leased or financed with Russian operators. These amendments have started to affect negotiations and re-negotiations of leases with Russian… – Continue reading
MUMBAI: Since last month, Indians with overseas bank accounts are receiving letters from offshore financial institutions, asking them to disclose ‘tax residency status’ before Christmas. If they don’t, banks holding these accounts would share whatever information they have on such account holders with the Indian government. Many account holders are… – Continue reading
The government’s planned changes to the tax law for South Africans working abroad – either permanently or on a long-term contracts – has brought financial emigration into sharp focus. Financial emigration is a formal process with the South African Reserve Bank (SARB) to change your tax status from “resident” to… – Continue reading
Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not… – Continue reading
The Internal Revenue Service released guidance Wednesday to give tax relief to residents of Puerto Rico and the U.S. Virgin Islands who have evacuated the islands or were unable to return because of Hurricanes Irma or Maria. The relief extends the typical 14-day absence period to 117 days (starting Sept…. – Continue reading
Recently, ANAF announced the introduction of new Split VAT rules, At the same time, though, the tax authority made changes[i] to the procedural tax law which have largely been overlooked in the intense debate over Split VAT. But unnoticed or not, these changes are important for businesses in Romania. Four… – Continue reading
In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading
Indians who are on deputation overseas or have settled overseas — whether by way of acquiring a permanent residency such as a green card in the US, or acquiring citizenship of a foreign country — need to be aware of their tax obligations in India. A recent move seeking details… – Continue reading
New data-sharing rules aren’t without pitfalls for clients of private banks, as authorities race to shut loopholes, Bank Reyl lawyer Drazen Turujlija told finews.asia-TV. Switzerland is set to begin exchanging data with other countries from next year, a move which has fundamentally shifted the dynamic in Switzerland’s trillion-Swiss franc offshore… – Continue reading
Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of… – Continue reading
In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more… – Continue reading
MOSCOW — Some of Russia’s super-rich have given up residency to escape a 2014 law requiring them to disclose offshore assets, wealthy businessmen told Reuters, a practice that could keep billions of dollars hidden from Moscow’s tax authorities. Interviews with more than a dozen people familiar with the practice —… – Continue reading
Some 9 million Americans reside abroad. More than 4 in 10 wouldn’t rule out renouncing U.S. citizenship, according to a survey. Americans abroad have just about had it with Uncle Sam’s tax filing requirements. Those were the findings from a recent survey of more than 2,100 U.S. expatriates, according to… – Continue reading
Transferring wealth to a spouse who isn’t a U.S. citizen can create complex gift, estate and generation-skipping transfer tax challenges. Such transfer tax issues require careful planning, as well as a clear understanding of the differences in how citizens and non-citizens are taxed. Unlike citizens and resident aliens, a non-resident… – Continue reading
Pretoria – South African financial institutions, which include banks, long-term insurers and asset managers, will have to exchange financial account information in terms of the common reporting standard for the first time this year. Financial institutions, although having to do similar exchanges in terms of the US’s Foreign Account Tax… – Continue reading
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at… – Continue reading
Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be… – Continue reading
It often occurs that a multinational company employs a foreign manager based on an employment contract or secondment. In the first case, the Hungarian company is considered as the legal and economic employer, therefore the salary is payed directly by it. In the second case, the employee maintains the employment… – Continue reading
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading
Property buyers will be quizzed about their tax residency under new anti-money-laundering rules being introduced by Westpac and its subsidiaries St George Bank, Bank of Melbourne and BankSA. Mortgage brokers, who act as intermediaries between the banks and buyers, are being told that from this week they must also ask… – Continue reading
Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first… – Continue reading
New guidelines aim to check tax evasion, ensure foreign firms are not taxed on their global income. New Delhi: The income-tax (I-T) department on Tuesday issued the final guidelines for place of effective management (PoEM) rules that seek to determine the residency status of a firm for calculating its tax liability. The… – Continue reading
SINGAPORE: Under the Common Reporting Standard (CRS) which has been in effect since Jan 1, Singapore-based Financial Institutions (FIs) are now required to establish the tax residency status of all their account holders, the Inland Revenue Authority of Singapore (IRAS) said on Friday (Jan 6). The CRS is an internationally… – Continue reading
Jean-Claude Juncker deliberately blocked the EU’s efforts to fight tax avoidance while in office as prime minister of Luxembourg, according to documents revealed by The Guardian and the International Consortium of Journalists. EurActiv France reports. Member states have supposedly spent the last two decades cooperating in the committee on business… – Continue reading
