Peculiarities of the double tax treaty between Italy and Germany
By Roberto M. Cagnazzo, Three & Partners
The Convention for the Avoidance of Double Taxation between Italy and Germany has several peculiarities compared to the OECD Model.
Canada’s residential tax regimes
By Elisabeth Colson and Bill Smith, Devry Smith Frank LLP
For years, Canada’s residential real estate market grew rapidly, resulting in significant foreign investment. Governments of all levels in Canada have created new tax regimes to curb speculation. This article provides an overview of these rules.
France is an attractive country to be tax resident
By Prof Robert Anthony, Anthony & Cie.
In France there is a forfeit tax of 30 percent on dividends. However, this is made up of 17.2 percent social charges and a 12.8 percent fixed rate of income tax. If one looks at the corporate tax rates in France of companies, one is taxed at 15 percent on the first EUR 42,500 of corporate profits and 25 percent thereafter.
Navigating the taxation of pensions in the US/UK Double Tax Treaty
By Arvinder Matharu, Prager Metis
A new client recently engaged me to handle a HMRC investigation opened into his UK tax return which was prepared by his previous UK accountant. Specifically, HMRC has queried a claim for double tax relief where the US tax paid was being claimed as a credit against the UK tax liability. On review, the following facts were relevant:
New Solution for Succession Planning: Family Foundation
By Piotr Prokocki, Penteris
A new law has just been published and will come into force on 21 May 2023. Its tax implications are widespread as it provides new solutions for succession planning.
Real estate tax reform in Germany
By Niels Webersinn, nbs partners
As a result of the new real estate tax, 36 million economic units in Germany must be revalued in 2022 due to the decision of the German Constitutional Court on 10 April 2018, which declared the real estate tax valuation based on unit values no longer valid. The standard values as of 01 January 1935 (eastern Germany) and 01 January 1964 (western Germany) will lose their validity on 31 December 2024.
Asset Management in times of uncertainty
By Camilo J. Gaona, FRG Auditores y Consultores S.A.S.
Two and a half years of pandemic and three months of social upheaval, coupled with economic tension due to the container crisis and the global effects of the war in Ukraine, have assessed the resistance of Colombian businesspeople. The widespread closure of both large, century-old companies, and more than half a million micro-businesses show the profound impact of the situation on the national economy.
The art of transferring cultural assets free of inheritance and gift tax in Germany
By Niels Webersinn, nbs partners
Collecting art is not only associated with a passion for art and culture. Popularly, this passion turns into a savvy capital investment approach due to the increase in value of art items collected, and eventually, the complete exemption from inheritance/ gift tax in Germany on these items.
Maltese pension plans under the Malta/US Income Tax Treaty
By Gregory Dean, USTAXFS
Over the past decade, pension plans have been established and licensed in Malta with particular consideration given to US taxpayers. A number of these plans were designed to accept “rollovers” from foreign pensions plans owned by US persons – most notably from UK pension plans – combining the tax deferral benefits of a Qualifying Recognised Overseas Pension Scheme (QROPS) for UK tax purposes and the perceived US tax deferral benefits of a Malta pension.
Special tax regime for impatriates: Requirements for application of the Beckham law
By Jesús Ruíz Ballesteros, Ruiz Ballesteros Lawyers and Tax Advisors
Known as the Beckham law, this tax regulation is widely used by foreign executives who come to Spain to work for their companies, because it allows them to pay income tax at a rate of 24% (up to EUR 600,000) instead of 45%. In order to apply this special regime, the following requirements must be met:
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