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
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading
On April 13, 2017, the Ukrainian Parliament ratified its tax treaty with Malta, which provides for lower withholding tax rates on dividends, interest, and royalties. Under the deal, the withholding tax rate for dividends would be capped at 15 percent. A special rate of five percent would apply to dividends… – Continue reading
Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons… – Continue reading
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP… – Continue reading
The DTA clarifies the taxing rights on all forms of income flows arising from cross-border business activities and seeks to ensure such income is not taxed twice. The agreement provides that withholding taxes on dividends, interest, and royalties will generally not exceed seven percent. Withholding taxes on service fees will… – Continue reading
On 14 March 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg “On Avoidance of Double Taxation and Prevention of Income and Capital Tax Evasion” (the “Convention”) and a protocol to it (the “Protocol”). As we informed… – Continue reading
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
The OECD and the International Monetary Fund have submitted to the Group of Twenty (G-20) nations a report on improving tax certainty for businesses. The report follows a global survey of more than 700 large, multinational businesses and a survey of 25 advanced nation tax administrations. The report highlights several… – Continue reading
The Swiss government plans to bolster group financing activities by amending its withholding tax ordinance to exempt interest payments for certain intra-group loans. The goal of the amendment is to encourage Swiss-based multinational companies to pursue targeted financing activities in Switzerland rather than abroad, according to a March 10 news… – Continue reading
The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading
Countries that end up on the European Union’s list of tax havens could subject companies operating within their borders to tax sanctions—such as withholding taxes and denied deductions for royalty payments—damaging the businesses’ ability to offset losses in the jurisdictions. Following a March 1 meeting, politicians identified a range of… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading
The importance of taxation to a nation’s economic wealth and development cannot be overemphasised. However, the achievement of this goal is often undermined by tax evasion and deliberate attempts by multinationals to shift profits from one jurisdiction to another, amongst others. Over the years, Nigeria has attempted to use taxation… – Continue reading
Enugu State government has sealed eight banks for failure to remit to its coffers about N1billion in withholding taxes said to have accrued since 2007. As early as 6.00 a.m. yesterday, enforcement officials of the State Board of Internal Revenue had stormed the premises of the affected banks and effected… – Continue reading
The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading
The signing of a double taxation agreement between the UK and the UAE in April 2016 was undoubtedly much anticipated and marks a new milestone in the successful expansion of the UAE’s international tax treaty network. Following ratification of the agreement by the two countries reacting parties, it came into… – Continue reading
THE scope of the withholding tax — a tax imposed on non-residents for services rendered to Malaysia-based companies — has been widened. It is one of the major tax changes that came into effect on Jan 17 under the Finance Act 2017. Under the changes, non-residents must pay withholding tax… – Continue reading
The Caribbean Association of Banks (CAB) has expressed concern about the number of countries in the region which have not yet put in place inter-governmental agreements (IGAs) with the United States on the Foreign Account Tax Compliance Act (FATCA). It said it was therefore renewing the call for Caribbean countries… – Continue reading
CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable… – Continue reading
Revenue appraisers began crosschecking the withholding tax returns from some companies to determine propriety of the pay disbursed to their foreign and local employees and consultants. In recent times, the submitted accounts on the pay-as-you-earn tax of some multinational companies (MNCs) and domestic firms have been under surveillance of the… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income… – Continue reading
India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading
The UK and Switzerland have terminated tax arrangements under the Savings Tax Directive and will instead share information in tax matters automatically under the Common Reporting Standard. The UK Government said, under the switch to the OECD’s Common Reporting Standard, UK taxpayers will no longer be able to pay a… – Continue reading
The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading
The US government is facing calls to delay the introduction of a new tax on foreign investors in US equity-linked derivative transactions, after the G5 group of countries signalled their opposition and the US Securities Industry and Financial Markets Association (SIFMA) indicated its members would not be ready for the… – Continue reading
South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes… – Continue reading
Two reports on company taxation show that more than a third of the largest companies operating in Australia paid no tax in 2014–15 and that multinational tax evasion cost an estimated $4.8 billion that year. These reports show the fraud of the claims being made by the Australian government and… – Continue reading
A recent report has revived claims Singapore is a tax haven but the Singapore Government and experts here reject the label emphatically. They say the report contains inaccurate assertions and fails to recognise recent steps here to crack down on tax evasion. The Republic ranked fifth on a list of… – Continue reading
Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading
The Governments of the United States and Grenada have signed the Foreign Account Tax Compliance Act (FATCA) that will enforce a requirement for US citizens to file yearly reports on their non-US financial accounts. “This allows us to work together to ensure that financial institutions here in Grenada can help… – Continue reading
The withholding tax (WHT) agreement between Switzerland and Austria will be terminated on January 1, 2017, when the agreement between Switzerland and the EU on the automatic exchange of tax information enters into force. On November 11, 2016, Switzerland and Austria signed an agreement to ensure a smooth transition between… – Continue reading
Practitioners in the managed funds industry are calling for a zero-rate for withholding tax in Australia amid the government’s proposals for new tax concessions to boost it, saying the proposed measures don’t go far enough. The government released a consultation paper Nov. 3 on non-resident withholding taxes for pooled funds—or… – Continue reading
The US Internal Revenue Service (IRS) has netted more than $10 billion in secret offshore cash and investments. The controversial Foreign Account Tax Compliance Act (FATCA) has encouraged more than 100,000 taxpayers to reveal their overseas holdings. But the IRS suggests this is just the start as FATCA cranks up… – Continue reading
The UK and Colombia signed a double tax agreement (DTA) on November 2, which is intended to support trade and investment by capping withholding tax on cross-border income. The agreement was signed by the Financial Secretary to the Treasury, Jane Ellison, and the Colombian Finance Minister, Mauricio Cardenas, during President… – Continue reading
A multinational company based in a jurisdiction that has no tax treaty with Israel must pay Israeli taxes on its Israel-related earnings from international money transfer services, the Israel Tax Authority determined. The ruling is set to apply to the growing number of financial service firms entering the Israeli market,… – Continue reading
The New Mexico tax department has agreed to stop automatically withholding income tax refunds from many foreign nationals without Social Security numbers who file under alternative identification numbers provided by the IRS, a New Mexico state senator said Friday. Sen. Gerald Ortiz y Pino said he co-signed the settlement as… – Continue reading
India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading
The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading
An extensive tax treaty that would shield Chinese businesses operating in the Kingdom from double taxation, and vice versa, has been drafted and is expected to be approved imminently, according to a senior Cambodian tax official. Experts said yesterday the double taxation agreement (DTA) would create a clear legal framework… – Continue reading
FATCA disclosure agreement takes effect, worrying some Israeli-Americans Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward,… – Continue reading
Department of Finance receives ‘unprecedented’ lobbying from property funds Overseas investors in Irish property may have to wait for a further two months for clarity on how the Government plans to tax structures they have used to snap up billions of euro of real estate after the financial crisis. The… – Continue reading
On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading
In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key… – Continue reading
The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading
Eight British overseas territories and crown dependencies, including Jersey, the British Virgin Islands and Cayman Islands, could face EU economic sanctions after Brussels identified them as having low or no corporation tax. Experts have published a scorecard showing red flag warnings set against a list of the 81 countries that… – Continue reading
