The French Ministry of Finance has issued guidance on the procedure for taxpayers to follow to reclaim wrongly charged social security contributions. The guidance has been issued following a European Court of Justice ruling in February in Ministre de l’Économie et des Finances v. Gérard de Ruyter. The case concerned… – Continue reading
The government has launched a consultation on tax avoidance policies related to interest deductions that could have significant consequences for real estate. The proposals were released by the the Organisation for Economic Co-operation and Development (OECD) as part of a series of recommendations earlier this month designed to prevent companies… – Continue reading
NEWARK, Del. — It may not summon up a sense of international intrigue like Geneva or Luxembourg, but this small city, just off the Interstate and down the road from Wilmington, can now boast that it has joined those more glamorous locales as a tax haven for art collectors. Fritz… – Continue reading
According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading
The Indian government’s initial unsuccessful efforts to unearth billions of dollars of undeclared foreign assets – some believed to be hidden in Swiss banks – highlight the complexity of vehicles used to move money illicitly. Earlier in the year, a new law on black money came into effect. It included… – Continue reading
Jakarta. The Indonesian government revealed its fifth stimulus package on Thursday in a bid to prop up the economy by, among others, scrapping double taxation imposed on companies called real estate investment trusts to improve property investment. The package was announced by Cabinet Secretary Pramono Anung, Coordinating Minister for Maritime… – Continue reading
Some might be surprised to learn that certain areas of Richmond and Vancouver, despite being thoroughly decorated with mcmansions, monster homes, and incessantly rising land prices, are actually inhabited by low income residents that make up a surprising per cent of the population. Conservative Party leader Stephen Harper, during a… – Continue reading
Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading
Sinisa Mali, the Mayor of Belgrade, has dismissed claims that he owns 24 apartments on the Bulgarian coast. Belgrade Mayor Sinisa Mali has denied a media report that he owns a string of properties in Bulgaria. In a statement, he said he owns only one apartment in Bulgaria, which he… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
x Australian Prime Minister Malcolm Turnbull announces his new federal cabinet during a media conference at Parliament House in Canberra, Australia, September 20, 2015. Australia got its fifth prime minister in as many years on Monday after the ruling Liberal Party voted to replace Abbott with former investment banker Malcolm… – Continue reading
No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading
Swiss firms have bagged major business from global brands such as GSK, Novartis and Crédit Suisse this year, while their Asia ventures have come good. The legal minds behind the Glaxo-SmithKline and Novartis asset swap, global banking investigations, Schaeffler’s €2bn high yield bond issuance and Dufry’s £1.05bn takeover of Nuance… – Continue reading
THAI property tycoon Khunying Sasima Srivikorn, who co-owns an English Championship football club, recommends the United Kingdom as the best location for offshore property investment after realising a double-digit yield from a recent investment in the country. Speaking at an exclusive forum recently held by Tisco Wealth and Forbes Thailand,… – Continue reading
A former head of Australia’s anti-money-laundering agency wants tough rules introduced to prevent the country from becoming a safe haven for foreign corrupt funds. Despite credible warnings that large volumes of illicit money leaving China are being laundered in Australia, an investigation by ABC programme Four Corners has found no… – Continue reading
As a newly-elected Australian lawmaker a decade ago, Malcolm Turnbull wrote an unsolicited 52-page proposal to reform the tax system. The report and its 281 recommendations were dismissed by the government and his costings called into question. Now, a month after replacing Tony Abbott as leader of the world’s 12th-largest… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
(CNS Business): Government faces some serious challenges over the next 18 months to update the regulatory regime that protects the country’s financial service sector ahead of a task force inspection in March 2017. Francis Arana, head of the Anti-Money Laundering Unit in the Attorney General’s Chambers, who is coordinating the… – Continue reading
The Russian government has approved legislation that would conceal property owned by state officials and would hamper anti-corruption investigations, Transparency International (TI) warns. The move to make the state property registry secret is not yet law – it still has to go before parliament. TI, an anti-corruption watchdog, said the… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading
New Zealand’s Inland Revenue Department (IRD) announced on September 23, 2015, that two new acts, the Land Transfer Amendment Act 2015 and the Tax Administration Amendment Act 2015, received Royal Assent to strengthen property investors’ tax compliance. Under the new legislation, three changes will apply from October 1, 2015, for… – Continue reading
It is estimated that only around 1% of the world’s population have two or more passports, making dual citizenship an exclusive privilege JOHANNESBURG – “No man is an island” is the theme of this year’s upcoming Investment Agenda, being held in Johannesburg on the 20th of October. Leading investors, asset… – Continue reading
Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading
The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to legal persons tax and that qualify as founders or third-party beneficiaries of so-called… – Continue reading
With a slim new book that has the feel of Piketty’s bestselling Capital in the 21st Century, Zucman, a 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6-trillion — about 8% of the world’s net financial wealth…. – Continue reading
MUMBAI: The promoter of a Delhi-based, mid-sized, listed company has a Rs 700-crore problem. The cash is in various overseas accounts but the businessman has no plans of declare it before the black money deadline of September 30. Instead, he plans to invest it in the Indian capital markets by… – Continue reading
International families are establishing domestic trusts at a record pace.1 Previously, these families set up trusts in the United States only if they had family and/or assets in the United States. This strategy still remains popular for international families, but now they’re also using domestic trusts even if they don’t… – Continue reading
Tax residency of Jersey companies Jersey companies may (contrary to the default position) be treated as exclusively tax resident in jurisdictions other than Jersey pursuant to Article 123(1)(a) of the Income Tax (Jersey) Law 1961. The criteria for a Jersey incorporated company to be resident (for taxation purposes) in a… – Continue reading
Look out, Thomas Piketty. Here comes Gabriel Zucman. With a slim new book that has the feel of Piketty’s bestselling “Capital in the 21st Century,” Zucman, a baby-faced 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6… – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading
Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading
All eyes are on how much taxes the British retailer Tesco Group will pay to the South Korean government after its profit of more than 5 trillion won (US$4.21 billion) with the sale of Homeplus. Industry sources say that the company will not have to pay taxes at all, or… – 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
Lawyer Patrick Poulin says he helped clients set up offshore corporations in the Caribbean. And that’s what he was working on when he flew to Miami from the Turks and Caicos last year to meet with two Americans who wanted him to invest $2 million from a real estate deal…. – Continue reading
Greece’s Alternate Finance Minister in the current caretaker government, Tryfon Alexiadis, has pushed for an overhaul of the controversial property tax ENFIA. The Single Property Ownership Tax (ENFIA) is widely seen as inequitable and has been deeply unpopular since its introduction on January 1, 2014. Earlier in 2015, the Syriza… – Continue reading
In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading
German business groups have hit out at Berlin’s plan to reform how it taxes investment funds, warning on Thursday that the proposed changes would hurt pension provisions and reduce the attractiveness of Europe’s largest economy as a place to invest. The finance ministry announced plans in July to reform the… – 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
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Offshore buyers, primarily from China, are driving demand for luxury properties in Canada, helping to fuel sales of multimillion-dollar homes in major markets outside of Alberta. More than 570 homes priced over $3-million sold in Vancouver in the first seven months of the year, up nearly 80 per cent from… – Continue reading
Greece’s Deputy Finance Minister, Trifon Alexiadis, has fired Greece’s first salvo in the fight to overcome the country’s non-compliance problems, announcing the introduction of a comprehensive scheme of asset registration for all taxpayers. The new “Asset Declaration” measure will apply from the beginning of 2016. In preparation, the tax authorities… – Continue reading
Foreign asset declarations by Spanish taxpayers have totaled EUR126.3bn (USD145bn) since 2013, when such declarations became compulsory, Spain’s Ministry of Finance has said. The Ministry said that in the past three months 1,813 taxpayers declared EUR1.9bn in foreign assets under Modelo 720, which requires tax resident individuals to report assets… – Continue reading
New investment structures are making it easier for people from outside of the European Union seeking to live in Portugal through the country’s golden visa programme, reports the Expats Forum. The initial minimum investment of €500,000 has been reduced to €350,000 for investment in properties located in districts designated for… – Continue reading
Investigator says Canadian real estate market has developed reputation as a place to launder money A report prepared for Canada’s anti-money laundering watchdog points to offshore cash in the real estate sector as a “significant risk” for criminal wrongdoing. The Financial Transactions and Reports Analysis Centre of Canada, commonly known… – Continue reading
