British expats in France can claim a share of millions of pounds of compensation after the European Court ruled in their favour against unfair social security payments imposed by President Francois Hollande’s government. Around 200,000 expats who have rented out or sold homes in France during the past three years… – Continue reading
HMRC has secured a hat-trick of tribunal wins against tax avoidance schemes, protecting over £260m in tax. All three rulings uphold earlier judgments in HMRC’s favour at the first-tier tribunal. The upper tribunal dismissed an appeal brought by users of a scheme promoted by NT Advisors, the taxman’s ninth successive… – Continue reading
This article continues our series on the Base Erosion and Profit Shifting (BEPS) project, and the Action Plans that have so far been submitted, by the Organisation for Economic Co-operation and Development (OECD). We now look at Action Plan 15 on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties…. – Continue reading
MUMBAI: Income-tax authorities on Friday issued draft assessment orders against nearly 150 foreign portfolio investors (FPIs) asking them to pay minimum alternate tax (MAT), a move that is bound to reinforce India’s reputation for aggressive tax enforcement. The 15-page draft assessment order sent to FPIs provides reasoning as to why… – Continue reading
Dividend payment by an overseas company with related assets in India will not be taxable in India, the govt says New Delhi: The income tax department on Thursday clarified that dividend payment by an overseas company with related assets in India will not be taxable in India, as part of… – Continue reading
HM Revenue & Customs (HMRC) has secured over £260 million after triumphing against three tax avoidance schemes in tribunal battles. The Upper Tribunal dismissed an appeal brought by the investors of a scheme promoted by NT Advisors. This was HMRC’s ninth win against schemes promoted by NT Advisors. According to… – Continue reading
The International Finance Corporation (IFC) has approached Finance Minister Ishaq Dar seeking withholding tax exemption on the payments made or transactions carried out by the IFC, through an amendment in the Second Schedule of the Income Tax Ordinance 2001 along with an exemption certificate from withholding tax provisions from July… – Continue reading
Following a period of consultation, legislation is to be included in the 2015 Finance Bill which will extend capital gains to gains accruing to a non-resident person on the disposal of a UK residential property. The charge will apply from 6 April 2015 to gains arising on or after that… – Continue reading
The India-Mauritius Double Taxation Avoidance Agreement (DTAA) may see some headway with the island nation promising full cooperation with India to address outstanding issues relating to their bilateral tax treaty. The development comes days after Prime Minister Narendra Modi visited Mauritius. Its Finance Minister Seetanah Lutchmeenaraidoo in his Budget speech… – Continue reading
While the U.S. has traditionally been seen as a low-tax jurisdiction for individuals, with its many exemptions and generous deductions, its rules can bite hard for U.S. expatriates. In the past, “long distance Americans” generally responded by ignoring their U.S. tax obligations, and expat filing rates were notoriously low. Now,… – Continue reading
Labour is instructing local parties to “minimise” tax when buying and selling properties, the Daily Telegraph can disclose. A leaked document reveals that Labour is advising their constituency parties on how to cut their tax liability and that of the national party. The disclosure will be hugely embarrassing for Ed… – Continue reading
Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation. However, below is a summary of some of the business related announcements: Diverted… – Continue reading
The governor released her budget for the biennium fiscal years 2016 and 2017 a month ago. The budget called for revenue $338 million more than the House Ways and Means Committee (HW&MC) estimates. On an apples to apples basis, a $100 million of the total is simply the governor’s more… – Continue reading
America’s tax code is riddled with problems. It imposes high rates on families, businesses, investors, and entrepreneurs. Its double taxation of capital gains and dividends creates a bias against savings and investment—activities essential for economic growth. Its convoluted system of deductions, credits, and exemptions distorts incentives and inefficiently allocates resources,… – Continue reading
The China State Administration of Taxation recently issued a notice extending the taxation of capital gains by non-Chinese tax residents arising from indirect transfers of Chinese assets. Where indirect transfers of equity in Chinese entities were already subject to capital gains tax based on Circular 698, Notice 7 now extends… – Continue reading
As discussed in prior posts, an asset sale transfers only the assets of the business, whereas a stock sale transfers some or all of the ownership interest in the business as well as its obligations and liabilities. In this continuing examination of how to structure a business sale, the next… – Continue reading
Living in Central Massachusetts, had I the vision of Sarah Palin, who can see Russia from her home in Alaska, I could look north and see New Hampshire on the right and Vermont on the left. It is perhaps an apt metaphor. New Hampshire with its “Live Free Or Die”… – Continue reading
Owning real property on both sides of the border can create a confusing tax situation. Consider this example. Stefan and Jane are married and live in Vancouver. Jane is a Canadian citizen while Stefan holds both U.S. and Canadian citizenship. In 1994, shortly after getting married, they bought a house… – Continue reading
The government has moved to legislate in haste to close tax loopholes. But history suggests this is unwise. One legal figure to crop up in the chancellor’s budget statement published yesterday was the ubiquitous Sir Brian Leveson. The president of the Queen’s Bench Division receives a namecheck in the budget’s… – Continue reading
The Abbott government is pushing ahead with a Labor budget measure to close a loophole that will stop giving offshore-based multinationals “systemic tax advantages” that are not available to Australian-owned companies. The loopholes in current law mean that multinationals can, with the use of subsidiaries, structure their affairs to avoid… – Continue reading
Towards the end of last December, the cabinet passed resolutions representing the latest attempt to turn Thailand into an attractive location in which to establish an international headquarters (IHQ). This is the third attempt in a little over a decade to lure multinational companies to Thailand. The first regional operating… – Continue reading
New Zealand has a broad-based tax system consisting principally of: income tax fringe benefit tax resident and non-resident withholding tax (RWT and NRWT) goods and services tax (GST) Accident Compensation levies import tariffs and miscellaneous excise duties, and local authority rates on property. Stamp duty, gift duty and death duties… – Continue reading
New tax charge A new regime which will charge non-UK tax resident owners of UK residential property to capital gains tax (CGT) is due to come into force on 6 April 2015. The draft legislation was published as part of Finance Bill 2015 on 10 December 2014, after an extensive… – Continue reading
Ireland is facing a fresh threat to its 12.5 per cent corporate tax rate, as MEPs begin investigating low rates across Europe, reports the Irish Independent. A 45-member EU Parliament Tax Inquiry Committee, formed in the wake of the Lux Leaks scandal, has been tasked with investigating various tax arrangements… – Continue reading
Rules are tangled and dispute resolution is excruciatingly slow. The government’s trying but it’s a long haul As Asia’s third-largest economy, India is a major investment destination. However, in recent years, the unpredictable tax regime has has been a major stumbling block to its potential. According to a recent World… – Continue reading
Add Ndamukong Suh to the ever-growing list of professional athletes who are bidding farewell to their high-tax home state in favor of sunnier economic climates. Suh – considered one of the top-two players in free agency this season – is leaving Detroit for Miami. By doing so, the defensive tackle… – Continue reading
Senators and members of the House of Representatives under the auspices of Anti- Money Laundering and Cyber Security Coalition are working with the Independent Corrupt Practices and other related offences Commission to prosecute about 115 tax offenders. The Chairman of the Senate Committee on Pensions, Senator Aloysius Etok, (PDP-Akwa Ibom),… – Continue reading
Republican Senators Marco Rubio and Mike Lee recently released a tax reform proposal that is a curious mix of principled pro-growth measures and populist middle-class relief. Where it sticks to principle, it is great. But where it veers into populism, the plan collapses into incoherence. The senators’ plan is a… – Continue reading
Citizenship has been turned into a commodity by countries including Cyprus, Grenada, Antigua, Malta and St. Kitts in the Caribbean, which is now the most popular place in the world to buy a passport – for as little as $250,000. The draw? Little or no tax. New citizens of St…. – Continue reading
Ruling by the European Court of Justice means France is liable to reimburse tens of millions of euros to British and other EU non-resident owners who let out or sold their properties France has lost its tax war against British second home owners after the European Union’s top court deemed… – Continue reading
There is a sense of déjà vu in tax and legal circles. Vodafone bought itself into Hutch’s Indian telecom operations by acquiring controlling interest in a Cayman Island company that called the shots in the Indian company hitherto controlled by Hutchison Hong Kong. The tax authorities slapped a notice on… – Continue reading
The regional operating headquarters (ROH) provisions that Thai tax authorities introduced in 2002 have never been popular, as they are difficult to understand and comply with. As a result, many businesses have bypassed Thailand and chosen Kuala Lumpur for their regional offices. Even a major revamp of ROH regulations in… – Continue reading
The long-awaited double tax agreements entered into by Kenya with South Africa and Mauritius respectively did not come into force on 1 January 2015 as expected. The treaty between Kenya and South Africa that was signed in November 2010 was ratified by Kenya in October 2014, following earlier ratification by… – Continue reading
Structures for investments from overseas investors in French real estate that involve Luxembourg vehicles may need to be restructured if an expected change to the double tax treaty between France and Luxembourg takes effect, an expert has said.09 Mar 2015 Property tax Property Tax Structured real estate Specialist property investment… – Continue reading
David Kuenzi of Thun Financial Advisors weighs in on the perils of U.S. expats investing in foreign mutual funds. Send your expat finance questions to expat@wsj.com. Keep an eye on WSJ Expat to see if your questions — and answers provided by our experts — are published. U.S. expat commit… – Continue reading
Many business owners have substantial personal assets invested in their business. This can have significant implications, not only for you and your business, but also for your family’s financial security. To protect your investment, both business and personal, your business strategy should include carefully structured tax-planning components to ensure you… – Continue reading
Discuss issues related to applicability of minimum alternate tax and permanent establishment Foreign Investor on Saturday raised several tax-related issues with Finance Minister Arun Jaitley at a meeting organised by the National Stock Exchange (NSE). According to sources, issues regarding applicability of minimum alternate tax (MAT) and permanent establishment (PEs)… – Continue reading
As a follow up to last week’s publication, below is a continuation of the article that highlights the requirements for filing returns, due dates and penalties for late filing of returns as it pertains to various tax types. Last week’s edition focused on Company Income Tax (CIT), Education Tax (EDT),… – Continue reading
Republican Senators Mike Lee and Marco Rubio have put forward version 2.0 of their tax reform proposal first released last September. The two men offer a bit more detail to their sweeping plan this time around, and it’s still a strong, pro-growth proposal. The broad strokes of the Lee-Rubio plan… – Continue reading
Double Tax Avoidance Agreement to be Applied to China Funds Investors no longer have to be worried about double taxation on China-based funds. On Mar. 4, the Korea Financial Investment Association told asset management firms to hand in documents for double tax avoidance agreement applications. Four months ago, when the… – Continue reading
NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top ten percent (in terms of income) of all taxpayers in 2015 will… – Continue reading
RAMALLAH, March 2 (Xinhua) — The Israeli withholding of Palestinian tax revenue dues would lead to full security deterioration in the Palestinian territories, a senior Palestinian official warned on Monday in an exclusive interview with Xinhua. Mohamed Mustafa, deputy prime minister of the Palestinian unity government and the minister of… – Continue reading
France has always been an attractive place to live but, there is a long-held perception that French taxes will eat up much of your income and savings, says Jason Porter, business development manager at Blevins Franks. Where annual income exceeds €1m (£729m, $1.1m), taxation at a rate of 75% (a… – Continue reading
Working overseas can lead to tricky tax pitfalls, but seeking expert advice can keep you from paying up twice. Going overseas to work is a grand adventure for many young professionals. It offers the opportunity to experience a different culture, expand your work experience and enhance future career opportunities. But… – Continue reading
The Conversation Five years ago the Henry Review undertook a detailed examination of Australia’s tax and transfer system. Today, the Tax and Transfer Policy Institute at ANU’s Crawford School has revisited the Henry Review, as the Australian government prepares to release its tax white paper. Tax reform should not be… – Continue reading
British mobile giant Vodafone hasn’t been bailed out, with Finance Minister Arun Jaitley maintaining status quo on taxing past offshore deals. However, foreign investors can draw comfort as tax will be charged in India only on certain offshore deals where the underlying asset and the value derived thereon are in… – Continue reading
The art of taxation, declared King Louis XIV’s Minister of Finances Jean-Baptiste Colbert, is in “so plucking the goose as to obtain the largest amount of feathers with the least amount of hissing”. The Budgets of Singapore and Hong Kong – released two days apart this week – have thrown… – Continue reading
Minister of Finance Martin Dlamini said the proposed revenue measures would assist government in mobilising additional resources for protecting essential services while Southern African Customs Union (SACU) revenues fall in the medium term. He said these initiatives include an amendment of the Income Tax regulations, including removal of the tax… – Continue reading
The income tax department has scaled down its estimate of income suppression by multinational corporations in India in the 2014-15 audit of intra-group cross-border transactions to Rs 47,000 crore, a steep 22% decline from the extra taxable income the department had attributed to the firms in the previous audit. The… – Continue reading
As part of the Autumn Statement it was announced that “The government will increase the annual charges of the ATED by 50% above inflation for residential properties worth more than £2 million for the chargeable period 1 April 2015 to 31 March 2016.” The Annual Tax on Enveloped Dwellings (ATED)… – Continue reading
