Category: Withholding tax rules

Real estate investment trusts may get taxation relief

CBDT to make provisions for MAT and reduce tax liability on Reits Jayshree P Upadhyay  |  New Delhi  January 9, 2015 Last Updated at 00:50 IST Real estate investment trusts (Reits), notified last year, have so far found few takers due to taxation-related issues. To address this, the Central Board… – Continue reading

The Anti-Inversion Rules of Notice 2014-52: A Trap for the Unwary ‘Blocker’

From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading

Tax Planning Considerations for the Purchase of a Residence in the U.S. by Foreign Buyers

Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading

Foreigner premium’ property taxes highest in Singapore and Hong Kong

Overseas property buyers have to pay significantly more tax than domestic buyers in Singapore and Hong Kong, making them the most costly places for foreigners to invest in residential real estate in Asia Pacific, says Knight Frank Singapore and Hong Kong are the most costly places for a foreigner to… – Continue reading

Taxing times

Businesses in the island’s vital financial services are gearing up for ‘substantial changes’ dealing with tax. That was one of the important messages to come out of a seminar organised by KPMG in the island. More than 200 experts attended the event which covered a series of changes in property… – Continue reading

Analysis of Asia’s Tax Rates, Part 2: Withholding Tax

A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

London mayor’s unpaid tax bill provides food for thought

You may have heard in the news about Boris Johnson. He’s a flamboyant politician in the U.K. with an unruly mop of blonde hair. Recently, he made news by publicly saying he absolutely won’t pay his U.S. taxes. And yes, he is the mayor of London (the “real” London, where… – Continue reading

Move to stop multinationals artificially loading debt overseas to dodge tax

The OECD is urging governments to tackle interest payments made by multinationals and their subsidiaries as part of a global crackdown on profit shifting. The aim is to also stop companies artificially loading debt in no-tax or low-tax jurisdictions to reduce their tax bills. It comes as the government backs… – Continue reading

Bad policy, good politics: Ed Balls’s determination to impose his mansion tax as soon as he can puts the Conservatives in a bind

“The religion of socialism is the language of priorities,” said Nye Bevan, Labour saint and creator of the National Health Service. Now we have discovered the principal priority of one of his heirs, Ed Balls; taxing the homes of the rich. The shadow Chancellor, once so relaxed about the wealth… – Continue reading

Lots of BEPS Output – What Outcome?

*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading

The Year of Transparency’s Tipping Point

More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading

New UK Capital Gains Tax

KOTA KINABALU: For Malaysian property investors, especially in the London property market where some Malaysian developers, welcomed by Mayor Boris Johnson are active in projects, the United Kingdom Government will introduce new Capital Gains Tax (CGT) on the sale of UK residential property with effect from April 6, 2015. Following… – Continue reading

Sebi bars 260 entities; suspects money laundering, tax evasion

Mumbai: In its biggest ever crackdown for suspected tax evasion and laundering of black money through stock trading platforms, Sebi Friday barred 260 entities, including individuals and companies, from the securities markets. While Sebi would further probe these cases, it has also decided to refer the matter to the Income… – Continue reading

Qatari ruling family hit with £38million stamp duty bill after using tax avoidance scheme on purchase of Chelsea Barracks

The Qatari ruling family has been ordered to pay £38million in stamp duty They used an aggressive tax avoidance scheme to avoid the huge bill Country bought 13-acre site from the MoD for almost £1billion in 2007 By LOUISE ECCLES, BUSINESS CORRESPONDENT FOR THE DAILY MAIL PUBLISHED: 01:57 GMT, 20… – Continue reading

Capital Gains Tax Changes for Expat Property Owners

Rules relating to the payment of CGT by non-resident UK property owners will change in April and expats will be affected. Significantly sneaky draft legislation was published last week that will affect the way capital gains tax (CGT) is charged on the sale of UK property assets owed by expats. … – Continue reading

Court upholds landmark ruling against tax avoidance

HM Revenue & Customs (HMRC) has protected up to £123 million in tax after a tax tribunal upheld a landmark ruling against a stamp duty land tax avoidance scheme. In July 2013, the HMRC won a case against Project Blue, which used the scheme. According to the HMRC the scheme… – Continue reading

The Best Job in the World

This is going to be the plum job for any international tax practitioner: Competent Authority for the Republic of Ireland. It seems pretty clear that the Base Erosion and Profit Shifting (BEPS) project will meet its announced deadline of the end of 2015 to produce final reports on all of… – Continue reading

Anti-corruption rules fail to force clarity on property ownership, MPs say

Coalition plan for stripping ‘cloak of secrecy’ from shell firms that leaves housing loophole slated by politicians and other critics Business minister Matthew Hancock unveiled ‘the first UK anti-corruption plan bringing action across the government’. Photograph: Jack Taylor/Barcroft Media Government plans to rip “the cloak of secrecy” from corrupt officials… – Continue reading

Luxembourg budget 2015 – main tax measures at a glance

Advance Agreements The so-called tax rulings and advance pricing agreements will be formalised by the introduction of appropriate provisions in the Luxembourg tax laws. By this means, Luxembourg will be able to offer as from 1 January 2015 a unified system providing taxpayers with legal certainty and a consistent and egalitarian… – Continue reading

Sebi says MF schemes with bonus option ‘not legitimate’

MUMBAI: The capital market regulator has plugged the loophole that allowed savvy mutual fund investors to lower tax by bonus stripping. The Securities and Exchange Board of India (Sebi) has spelt out that it’s not in favour of fund houses launching new schemes with bonus option in their arbitrage funds…. – Continue reading

The inversion backlash

Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading

The OECD action plan on Base Erosion and Profit Shifting

IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading

Exemptions, concessions: FBR suffers Rs 361 billion annual loss

The Federal Board of Revenue (FBR) is suffering massive revenue loss of Rs 361 billion per annum on account of estimated tax expenditure in direct taxes, ie, equivalent to 1.6 percent of the Gross Domestic Product (GDP) as a result of exemptions and concessions to various sectors. Former Finance Minister… – Continue reading

UK Finance Bill 2015 — Draft Clauses Published

This Alert provides more details on the most significant measures contained in the draft Finance Bill. Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most… – Continue reading

1 FATCA and trustees: part I

Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015?  Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading

Beating the big business tax minimisation schemes

Peter Mac Swedish “flatpack” furniture manufacturer IKEA has suffered a number of blistering mass media attacks for business practices that reduce their Australian tax liabilities to a tiny fraction of the company’s profits here. The criticism is certainly justified. Most ordinary working taxpayers, as well as companies that don’t engage… – Continue reading

Ireland: Property Investment Structures In Ireland: Irish Investment Opportunities

In recent times there has been a welcome return to activity in the Irish real estate market. Overseas investors have been circling and private equity groups have started investing heavily in Irish real estate amid confidence that the Irish economy has stabilised and is returning to growth. In this briefing… – Continue reading

Arcade operator, farmer and company director top tax defaulters’ list

A Dublin-based amusement arcade operator, a Co Sligo farmer and a Dublin company director topped the latest list of tax defaulters. The 107-strong list, published by the Revenue Commissioners, made settlements totalling €19.64 million. The largest settlement was made by fair and amusement arcade operators Groundview Limited, of 15 Lower… – Continue reading

FEDS SUE DEUTSCHE BANK FOR TAX FRAUD DATING BACK TO 2000

NEW YORK (InsideBitcoins) — Federal prosecutors with the U.S. Attorneys Office in Manhattan are suing Deutsche Bank, stating that the German bank owes the US Government roughly $190 million in unpaid taxes. The claims of tax evasion stem from gains related to the sale of Bristol-Meyers shares in 2000. Prosecutors… – Continue reading

American citizens like Boris must pay more tax, says US ambassador to UK (but Google and Amazon are doing nothing wrong)

Ambassador to London Matthew Barzun says US citizens must pay up Boris Johnson was born in New York so faces a tax bill in America London Mayor has branded the Transatlantic rules ‘outrageous’ Barzun defends US firms like Amazon and Google over tax dodging Insists they are just playing by… – Continue reading

B2B: Beneficial Owner of Income: Treaty Benefits and the Introduction of the New Rules

The MT Conferences section did not involve the reporting or the editorial staff of The Moscow Times. Russian business is trembling in expectation of the new year when major changes recently introduced to the tax legislation will enter into force. There has been a lot of discussion regarding the increase… – Continue reading

The Country Has Spoken

While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading

Property Council Pushes for Tax Reform

The Property Council of Australia has joined efforts by the broader business community to lobby the federal government to implement significant tax reforms next year. Members of the Business Coalition for Tax Reform (BCTR) will meet with the Australian Council of Social Service (ACOSS) on December 15 to commence discussions… – Continue reading

Peru Capital-Gain Tax Suffocates Stock Market, Exchange Says

The Lima Stock Exchange urged Peru to eliminate a 5 percent capital-gain tax on equities, saying it has deterred investors and contributed to a drop in trading volume over the past five years. The country’s weighting in global portfolios has fallen 40 percent since 2010, and the tax has helped… – Continue reading

North America leads global increase in MAP uptake

The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show. There were 1,910 new MAPs in 2013, a 14% increase from 2012, when there were 1,678 new MAPs. North America accounted for most of this growth, with… – Continue reading

UK: Switzerland UK Autumn Statement 2014 Analysis

In yesterday’s Autumn Statement, the UK Chancellor announced several measures that will directly affect non-UK individuals who live or own property in or are considering moving to the UK. Although in many cases the measures will mean that such individuals are liable to pay more tax in the UK than… – Continue reading

AREF welcomes UK’s proposed stamp duty land tax relief

John Cartwright (pictured), Chief Executive of the Association of Real Estate Funds (AREF), comments on the UK government’s objective to introduce stamp duty land tax relief in 2016… We welcome the government’s intention to introduce a stamp duty land tax (SDLT) relief for seeding investment – a much needed removal… – Continue reading

Malta should brace itself for tax haven clampdown – AD

Greens say Malta should start thinking of Plan B on its attractive tax regime for foreign companies as pressure from major EU states on European Commission grows Malta should be prepared to diversify its current fiscal policy and even wave goodbye to its incentives to attract foreign industry, Alternattiva Demokratika… – Continue reading

India’s Bilateral Investment Treaties Leave Room for Abuse

In December 2013, despite an ongoing official review of its existing agreements, the Indian government signed a bilateral investment treaty (BIT) with the United Arab Emirates. Information on the deal was recently made public by the Ministry of Finance after persistent efforts by civil society groups. Earlier in 2013, the… – Continue reading

Mauritius Overtakes Singapore as India’s Top Source of FDI

DELHI – Mauritius has overtaken Singapore as the largest source of foreign direct investment (FDI) in India, it was announced earlier this week. During the April-September period, Mauritius emerged as the strongest contributor of investment with an inflow of $4.19 billion. During the same period, Singapore provided $2.41 billion in… – Continue reading

Dechert OnPoint: Georgian Law Developments – Talking Taxes

Dechert Georgia, through the contribution of partners Archil Giorgadze and Nicola Mariani joined by senior associates, Ruslan Akhalaia and Irakli Sokolovski, is partnering with Georgia Today on a regular section of the paper which will provide updated information regarding significant legal changes and developments in Georgia. In particular, we will… – Continue reading

UK: Capital Gains Tax On Non-UK Residents

Late yesterday afternoon the Government published its response to the consultation on extending Capital Gains Tax (CGT) to non-UK resident owners of UK residential property.  This is the latest step in a series of significant changes in the last couple of years to the tax treatment of UK residential property…. – Continue reading