1907, 2017

Tutta Fuffa e Niente Arrosto

Further to the supposed revelations of the Malta Files, an interesting article which appeared in the Italian news portal  Mercati 24 tackled and commented upon the issue. The link to the article is this: https://www.mercati24.com/malta-files-tutta-fuffa-e-niente-arrosto/ [...]

1707, 2017

Brief summary of the Foreign Contractor Withholding Tax (FCWT) regime currently applicable in PNG

This article presents you with a brief summary of the Foreign Contractor Withholding Tax (FCWT) regime currently applicable in PNG. It incorporates the recent amendments introduced in recent budget. Who is liable to FCWT? Any [...]

1407, 2017

Greek Co. Not Liable For $4M Gain From Sale of US Partnership Interest

The Tax Court has concluded that a foreign corporation's proceeds from the redemption of a U.S. limited liability company that was treated as a partnership for U.S. income tax purposes was not U.S.-source income and [...]

1207, 2017

Federal Tax Day – Current,T.1,White House Committed to Tax Reform This Year, Mnuchin Says,(Jul. 11, 2017)

Treasury Secretary Steven Mnuchin has reiterated the Trump administration’s goal of achieving comprehensive tax reform in 2017. "We’re absolutely committed to getting tax reform done this year," he said in a July 9 televised interview. [...]

1007, 2017

Cross border GST transactions of digital products and services

GST on services and digital products: From 1 July 2017, goods and services tax (GST) will apply to cross-border supplies of imported services and digital products sold to Australian consumers. Note from the outset: The [...]

707, 2017

Investment Fund Set-up

The Luxembourg investment fund industry is largely benefiting from its location in a strong financial center. The greatest asset of Luxembourg is a constant anticipation of the needs of investors in order to create a [...]

507, 2017

New International Tax Treaty Landscape for China and Hong Kong

On 7 June 2017, senior officials and representatives of 67 jurisdictions (including Mainland China, who also represented Hong Kong SAR) gathered in Paris to participate in the signing ceremony for the Multilateral Convention to Implement [...]

307, 2017

Enhanced Dutch innovation box has been approved

The enhanced Dutch innovation box has been approved and has been found not to be harmful. This conclusion is drawn by the European Code of Conduct Group. This has been announced by the Dutch State [...]

2806, 2017

Transfer pricing of Inter-Company debt into Australia

The Full Federal Court has affirmed the decision of a single judge of the Federal Court, that Chevron Australia had not discharged its burden of proof that it had made an arm's length agreement to [...]

2206, 2017

Automatic Exchange of Financial Account Information (AEOI) – A matter of compliance for wealthy Chinese citizens?

In 2014, the Global Forum endorsed the new common reporting standard on automatic exchange of financial account information (AEOI). Jurisdictions that have publicly committed to implementing the AEOI standard on a timeline will first exchange [...]

1906, 2017

The Romanian government has recently adopted new measures to combat tax evasion and tax planning

The Romanian government has recently adopted new measures to combat tax evasion and tax planning by regulating the mandatory automatic exchange of information from reports that multinational enterprise groups are due to submit to the [...]

1406, 2017

Malta: A Start-Up Heaven

With Malta’s central position in the Mediterranean and the United Kingdom’s Brexit procedures soon to be implemented, the time is just right for Malta to gain traction and rank as a possible relocation destination for [...]

1206, 2017

Special Limited Partnership (SLP) as an Alternative Investment Fund solution

The SLP can be setup as an unregulated alternative Investment Fund under the AIFMD The Special Limited Partnership is a form of companies which can be incorporated in Luxembourg by one General Partner (GP) and [...]

806, 2017

The permanent establishment in international tax law

The significance of a permanent establishment in international tax law Corporate profits are taxed in full in the state in which the company’s registered office is located. This basic principle also applies in cases where [...]

506, 2017

Great new follow up article about the US three-year long Swiss Bank voluntary disclosure program that ended January 2016

A three-year long Swiss Bank voluntary disclosure program that resulted in non-prosecution agreements with the Department of Justice, netted 80 Swiss banks coming forward to reveal how they helped Americans evade U.S. income taxes and [...]

106, 2017

Flat Tax: Italy opens its doors to the rich not residents

The provision of Agenzia delle Entrate, 8th March 2017, operationalize the provision of Article 1, paragraph 152, of Law December 11, 2016, n. 232 (2017 Legge di Bilancio), which entered into Tuir the article 24-bis. [...]

2405, 2017

Have undeclared income from Foreign Accounts? The OVDP program may end after 2017?

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock. The window to Voluntarily Report Foreign Accounts in order to mitigate IRS Penalties May Be Ending After 2017. According to Tax Analysts [...]

1805, 2017

Post-Business Tax to VAT Reform (“B2V Reform”) in China

Since 1 May 2016, Business Tax has no longer been under China’s indirect tax regime and this signifies the completion of the B2V Reform in China.  The VAT chain in China is completed for largely [...]

1505, 2017

How to Get Profit from Investment in Property in Ukraine – a Guide for Investors

The real estate market of Ukraine is still very promising, despite the presence of conflict in the eastern part of the country. Especially if it is viewed from the perspective of investing by non-residents: the [...]

1105, 2017

Hong Kong – Updates on automatic exchange of information

Hong Kong has signed agreements with two more jurisdictions – South Africa and Portugal, in addition to six others last month, namely Belgium, Canada, Guernsey, Italy, Mexico and the Netherlands, for conducting automatic exchange of [...]

905, 2017

1st US Prosecution for “FALSE” Expatriation Statement

On February 13, 2017 we posted US Taxpayers & Their Advisors Doing Jail Time for Failing to Declare Offshore Bank Accounts! where we discussed that the IRS hunt for offshore income and accounts continues unabated well [...]

505, 2017

Law on takeover of joint stock companies – Serbia

This Law shall apply to takeover of the joint stock companies with the registered office in the Republic of Serbia, if the shares issued by such companies are traded on a regulated securities market. Within [...]

305, 2017

Malta’s imputed tax system to stay intact

According to Malta’s Finance Minister Edward Scicluna the Malta full imputation tax system is to stay ‘intact’, however there shall be a few technicalities in regard to the refunds that might have to be revisited [...]

2104, 2017

Back-to-back overseas loans to Australia

Historically, it was not uncommon for Australian resident taxpayers to borrow from a foreign bank, the loan secured over a deposit made with the bank by a non-resident associate of the taxpayer i.e. a “back-to-back [...]

1904, 2017

Adjustments in the Value Added Tax Law in Turkey

Some new arrangements have been made in the value added tax law to be implemented as of 1/4/2017. These new arrangements are made below; Exemption from VAT on the Delivery of Housing or Workplace To [...]