Taxation

Tax Regime for Non-Regular Residents in Portugal: A Competi­tive Advan­tage Beyond Borders

By José Alves do Carmo and Tânia Sofia Rosário, AVM Advogados

Sun, sea, reduced cost of living, safety, but mainly a lower tax burden. Portugal has long since ceased to be just a country at the tail of Europe. Its potential is known globally, being one of the most sought countries for investing and establishing residence. Approved in 2009, the Tax Regime for Non-Regular Residents (NRR) is yet another step towards international tax competitiveness.

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Taxation

The new special “res nondom” tax regime in Italy

By Prof Stefano Loconte and Angela Cordasco, Loconte & Partners

On the basis of the successful experiences recorded by some foreign countries (e.g. the UK, Portugal and Malta), Italy has introduced the “resident nondomiciled” regime for all individuals who want to transfer their residence in Italy after having lived abroad for over nine years.

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Taxation

Ownership Taxation in France

By Prof Robert Anthony, Anthony & Cie

Naturally, foreign property owners wish to invest in a way which protects their inheritance and minimises their taxes. France is known to be a high tax jurisdiction. Currently, wealth tax exists, although this may no longer be the case under a new conservative government.

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Taxation

Swiss Parliament eases dispute about the withholding tax notification procedure

By Marc Nideröst, Treuhand- und Revisionsgesellschaft Mattig-Suter & Partner

According to a partial revision to the withholding tax law which was approved by the Swiss parliament at the end of September 2016, the notification procedure is applicable for dividend payments to a holding company with a participation of at least 20%, even if the notification has not been filed within 30 days after the due date of the dividend payment.

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Taxation

UK non-doms taxed after 15 years! Do I stay or do I go?

By Prof Robert Anthony, Anthony & Cie

In its recent budget legislation, the UK government made a change which affects the tax paid by residents who have lived in the UK for more than 15 years while earning income from abroad. For many years, the UK has attracted a number of Asian, Middle Eastern, African, South American, European and more recently Eastern European individuals who do not have to pay tax on their worldwide income. U.S. nationals who are taxed on their worldwide income will not be as affected as others, as it is the effective rate of tax which could be an issue.

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Taxation

Death Tax and double tax on international estates

By Robert Worthington, Shea Nerland Calnan LLP

High net-worth individuals often have peripatetic lifestyles, being domiciled in one country, with assets in that country and elsewhere, and possibly family members residing in other countries for work, education, or lifestyle reasons. The tax that is imposed on the death of such people can be quite harsh to their estate or heirs. The harsh results are due to differences in the legal and taxation systems with imperfect, or a complete lack of, credit mechanisms or other means to eliminate double taxation. Most major countries have a network of tax treaties to prevent double taxation, but unfortunately most of these treaties only apply income taxes and not the types of taxes exacted on death.

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Taxation

Changes to Polish income taxes in 2016

By Artur Plutowski, EFS Group Sp. z o.o.

Transfer pricing

In summary, the revision of reporting obligations under the BEPS results in the following changes to transfer pricing:

  • Local file: an entity of a multinational group (annual revenue or costs above EUR 20 million) will be required to provide: a master file report containing standardised information relevant to all group members and (ii) a local file specifically related to transactions carried out by said entity.

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Taxation

The UK – Major Changes for Foreigners

By Graham Busch, Lawrence Grant

The past 12 months or so has seen some of the most significant developments in many years affecting people coming to live in the UK or investing in the UK. These include:

  • An end to the long-term non-domiciled status
  • Tax on the gains on all sales of residential properties
  • See through for Inheritance Tax on UK residential properties held in offshore companies
  • Main residence election
  • Some good news

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Taxation

Why are Indian citizens and businesses being asked to sign FATCA Declarations?

By Raghu Marwah, R N MARWAH & CO LLP

On 9 July 2015, India entered into an Inter-Governmental Agreement (IGA-1) with the United States of America under which it has been agreed to share data on a reciprocal basis with regard to the financial holdings and interests of U.S. residents in India and Indian nationals in the USA. Similarly, on 3 June 2015, the Indian government signed the OECD’s Multilateral Tax Treaty aimed at establishing a Common Reporting Standard for all partner jurisdictions. But what is FATCA and why does it sound so alarming?

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