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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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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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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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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