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.
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.
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.
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.
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.
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:
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:
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?
By Graeme Saggers, Nolands
The introduction of a withholding tax on interest paid to non-residents in South Africa was first announced in 2012. Since then it has seen a number of delays as legislation and systems have been refined. However, it finally came into official effect on 1 March 2015. The withholding tax is applied to all interest to foreign residents (excluding those with permanent establishments in South Africa or who are present in South Africa for more than 183 days in a year) which was or is paid or became due and payable after 1 March 2015.
By Artur Plutowski, EFS Group Sp.z.o.o.
Last year the European Court of Justice (ECJ) issued a judgement in case DFA Investment Trust Company vs. the Head of Tax Chamber in Bydgoszcz (C190/12). Generally, the case concerned investment funds benefiting from exemption in income tax (CIT). In particular, it referred to whether such exemption may depend on where the registered office of the investment fund is located.
