Portugal’s non-habitual residence (NHR) regime – 10 years of tax benefits
You may consider moving to the Algarve for a healthier, more relaxed lifestyle. ... - Continue reading
Category: Withholding tax rules
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
Canada: Taxpayers Must Pay Interest On Non-Existent Tax Debts
Following a transfer pricing audit, the Bank of Nova Scotia (BNS) entered into a settlement with the CRA on March 13, 2015, whereby certain amounts would be included in its income for the 2006 to 2014 taxation years. ... - Continue reading
Frydenberg welcomes historic OECD tax agreement
More than 130 countries agreed on Friday to rolling out historic changes to international tax rules, after leaders agreed to a new global minimum tax rate of 15 per cent targeted at companies with annual revenue of more than 750 million euros. ... - 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 readingOften Overlooked Exception to Withholding and Reporting Requirements under FATCA
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. ... - 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
Income tax implications for Indian investors investing in the US Stock Market
Indian investors are now proactively looking to diversify their portfolios overseas. We have seen the resilience and the outperformance of the US markets and we want in. ... - 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
Australia’s resident expats on cusp of losing CGT exemption
The new Budget - Not too welcoming to Australian expats. ... - Continue reading
PSX urges govt to eliminate or reduce CGT for two years
The Pakistan Stock Exchange (PSX) has a few proposals to the government in an effort towards reform. ... - Continue reading
Revenue-neutral incentives proposed for capital market growth
Proposals from the Pakistan Stock Exchange for the upcoming budget. ... - Continue reading
UK: Budget 2020 – Analysis
Main tax highlights of UK's Budget of 11 March 2020. ... - Continue reading
Norway proposes new withholding tax on some related-party payments
Authorities of Norway come up with new withholding tax rules. ... - Continue reading
In Depth: The Race To Beat Australia’s Capital Gains Tax Deadline
Thousands of Australian expats have until 30 June to sell their family homes or face being slapped with a hefty tax after the government reversed its position for exemptions. ... - Continue reading
Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between
On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2 ... - Continue reading
Nigeria: FIRS Issues Information Circular On The Claim Of Tax Treaty Benefits In Nigeria
The FIRS has issued a public notice on the claim of treaty benefits in Nigeria. ... - Continue reading
Expats to lose CGT benefits
Australian property owners living and residing abroad would have to sell their properties before June 2020 to still take advantage of capital gains tax (CGT) exemption. ... - Continue reading
An Overview of Taxation on Nonresident Individuals in Kazakhstan
Individuals not resident in Kazakhstan are subject to taxation on certain Kazakhstan-source income. ... - Continue reading
Australian expats to be hit with hefty tax
Australians living and working overseas have until June 30 to sell their family homes or face being slapped with a hefty tax after the government reversed its position for exemptions. A A$581m federal government plan to change capital gains tax arrangements for expats originaly lapsed, but the Australian government is… – 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
UK: UK Tax On Property For Non-UK Residents – Recent Changes
From April 2019, all direct disposals of UK land and property by non-UK residents are now subject to UK tax on capital gains ... - Continue reading
New Zealand, Guernsey sign tax treaty protocol
The governments of New Zealand and Guernsey on September 18 signed protocol to their tax information exchange agreement, the New Zealand government has announced. ... - Continue reading
Canada: Canada Ratifies The Multilateral Instrument
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - 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.
- 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.
Ireland proposes sweeping changes to transfer pricing laws
The government brought into legislation a specific element of the 2017 OECD guidelines that permits the tax authority to re-characterize an intra-group arrangement. ... - Continue reading
If PIO is non-resident, no tax needs to be paid on sale of foreign properties
NRI taxpayer may choose to invest long-term capital gains in another house property or purchase capital gains bonds to prevent taxation of capital gains ... - Continue reading
Will a new direct tax law push up compliance?
- Numerous amendments over five decades, as well as the influence of case laws, often made it difficult to interpret the rules
- India is rewriting its direct tax law to make it simpler, more sophisticated and less prone to disputes.
Three different routes to save tax on long-term capital gains
There are provisions under different sections of the Income-tax Act that can help you save on LTCG tax ... - Continue reading
Tax reform: Could Ukraine do it like Costa Rica?
In 2016, Costa Rica’s economy grew at a good 4.2% of GDP, but this year this figure is comparable to Ukrainian tortoise runs (we have 2.7% they have 2.9%). The success recipes of highly developed countries are in many cases not applicable to low-income countries such as Ukraine. Therefore, it… – 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
UK Finance Bill 2019-20: what international businesses need to know
Draft legislation and explanatory notes to the UK Finance Bill 2019-20 were published on 11 July. Much of the legislation was anticipated with some further clarifications provided. ... - Continue reading
