Fund Managers’ Carried Interests will be Taxed at 26% in Italy

By Prof Stefano Loconte and Angela Cordasco, Loconte & Partners

In order to make Italy more attractive for relocating private equity partners, Decree n. 50 of 24 April 2017 has officially approved the new withholding tax rate for their carried interests. The new regulation is very favorable, considering the current European scenario after Brexit, since many equity partners must decide in which EU member state they should establish their company’s headquarters and whether to keep their EU passports.

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The Trust Instrument and the New Res-Non-Dom Italian Regime

By Prof Stefano Loconte and Francesca Paulon, Loconte & Partners

We would like to say a few words about two of the biggest revolutionary fiscal developments Italy is experiencing: the new Italian ‘res-non-dom’ regime and the less new (but currently in the status of being reformed) trust instrument.

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Rent of Real Estate in Mexico: Tax Opportunities for US Residents

By José Carreras Benitez, INTEGROUP S.C.

Mexico has been considered a very attractive country for foreign investment. Residents abroad have acquired real estate in Mexico, mainly for relaxing, retirement purposes, and weather conditions. It is very common for US residents to stay in Mexico from October to March of the following year. Sometimes, US residents decide to rent such real estate, which means they are triggering taxable revenues for Mexican purposes.

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Load, Aim, Misfire! A look at the practical implications of the additional 3% SDLT rate

By Alex Barnes, Memery Crystal LLP

It’s almost a year now since the Government in the UK introduced the additional 3% Stamp Duty Land Tax (SDLT) rate on certain purchases of dwellings. This was no doubt done partially to raise revenue, but in the main was probably to appeal to voters by once again targeting those ‘nasty wealthy landlords’. As is often the case with new or additional taxes, this tax hike is prone to misfire and in many cases it’s not those that the Government was probably seeking to target who actually bear the brunt of the change.

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Why Should I Move My Residence to Portugal?

By Sérgio Ramos, Pontes, Baptista & Associados

What is a Non-Habitual Resident (NHR)? One of the principal objectives of this regime was to attract individuals and their families to Portugal by making it beneficial from a tax perspective to become tax resident in Portugal. The NHR regime provides a flat income tax rate of 20% for certain Portuguese employment and self-employment sourced income.

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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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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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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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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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