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Taxation Law Articles

Articles written by lawyers and expert witnesses worldwide
explaining the different aspects of Taxation.

Failure to File Charges, Ignorance and Deliberate Ignorance

  October 26, 2016     By HG.org
If a person fails to file his or her tax return when required to do so, he or she may face significant penalties based on a failure to file charge. Being aware of the defenses may help a defendant avoid the most serious consequences. However, defendants should also be aware of the limitations of these defenses.

Failing to File a Tax Return and the Willfulness Element

  October 26, 2016     By HG.org
When someone fails to file a tax return and is then charged with a crime of this nature, they often wonder why they were targeted for this crime. After all, there are criminals who have not filed tax returns for years because of their illegally-acquired funds. Often, the question comes down to the willful nature of the failure.

Auditor’s Approval in Hungary Is No Guarantee that NAV Won’t Fine You

  September 26, 2016     By Jalsovszky Law Firm
It’s common knowledge that in Hungary, calculation of the corporate tax liability is based on the items recognised in the accounting books. But a nasty surprise could lie in store for taxpayers who think they can apply the principles of accounting recognition fully in the course of calculating corporate tax.

Taxation in Agriculture in Ukraine

  September 21, 2016     By DLF Attorneys at Law
The main provisions of the Ukrainian legislation governing taxation in agriculture are embodied in the Tax Code of Ukraine, which regulates the special tax regime in the agricultural sector. Ukraine’s tax law provides certain tax benefits for agricultural producers.

Setting up a Company in Cyprus

  September 19, 2016     By Danos & Associates LLC
Having one of the lowest corporate tax rates in Europe and a wide network of double tax treaties, Cyprus is a very attractive and established jurisdiction for registering companies. The country is well known for the high standard of service providers such as law firms and accountants. English is widely spoken and the country has a pro-business environment and investor-friendly mentality. This article examines the advantages and process of setting up a company in Cyprus.

Taxes in Ukraine: Corporate Income Tax

  September 19, 2016     By DLF Attorneys at Law
Corporate Taxpayers: Corporate Income Tax (CIT) is paid by the resident companies, which receive income in Ukraine as well as abroad. CIT is also paid by the non-resident companies, which receive income from Ukrainian sources.

Thailand Board of Investment– International Headquarters and International Trading Centres

  September 8, 2016     By Harvey Law Group
Thailand’s reputation is that of a business-friendly country and together with foreign investment has made it a leading centre of trade in Southeast Asia. Thailand has emerged as an internationally recognized destination for service and industry sectors with tax incentives, well-developed infrastructure, cost-effective workforce as well as ideal geographic location.

Non Israelis – 10 Essential Tips When Purchasing Residential Property in Israel

  September 13, 2016     By Barnea & Co. Law Offices
Purchasing a residential property is generally one of the most profound, expensive and important decisions you make in your life. Even more so when purchasing a residential property in Israel.

Reverse Vesting and Holdback – Good News for Entrepreneurs in Israel?

  September 13, 2016     By Barnea & Co. Law Offices
“In this world nothing can be said to be certain, except death and taxes.” Benjamin Franklin strikes again. However, in the world of high tech and Israeli tax there has been some uncertainty as to whether entrepreneurs, whose shares are subject to a reverse vesting mechanism or a holdback upon their sale, should be paying income or capital gains tax.

From Business Tax to Value Added Tax – Further Tax Reform in China

  September 6, 2016     By Angela Wang & Co.
On 24 March 2016, the PRC Ministry of Finance (“MOF”) and the State Administration of Taxation (“SAT”) jointly released the Notice on the Comprehensive Roll-out of the Business Tax (“BT”) to Value Added Tax (“VAT”) Transformation Pilot Programme (Circular Caishui [2016] Number 36) ("Circular").

Inheritance Tax Where Estate Includes Real Estate

  August 29, 2016     By GRP Rainer LLP
In succession cases involving real estate, it is particularly important to pay attention to details when it comes to inheritance tax. Those who are not careful may be asked to pay up by the exchequer.

Tougher Approach Against Tax Evasion in Germany – Submit Voluntary Declaration on Time

  August 26, 2016     By GRP Rainer LLP
Germany’s federal and regional state governments want to step up their measures once again in the fight against tax evasion and hang out tax havens to dry. Voluntary disclosure leading to immunity represents a way out for tax evaders.

India Passes Constitutional Amendment to Pave Way for Goods and Services Tax

  August 18, 2016     By Rajkishore Associates
The two houses of the Indian Parliament recently passed an historic bill which aims to enact a common goods and services tax (GST) among the federal and the state governments of the Republic of India.

Tax Evasion in Germany: Voluntary Declaration Requires Professional Assistance

  August 12, 2016     By GRP Rainer LLP
The legislature has deliberately maintained the option for tax dodgers to return to a state of tax compliance by means of voluntary disclosure leading to immunity. Professional assistance is vital in this context.

How To Find Out What Is in the Canada Revenue Agency’s Files about Your Audit

  August 9, 2016     By LexSage
Wouldn’t you like to know what is in the Canada Revenue Agency’s (“CRA”) files concerning your GST/HST audit?

How to Claim Refunds for Overcharged Import Taxes Due to Surveillance Certificate Requirements in Turkey

Ministry of Economy determines certain minimum thresholds for certain products in order to force the exporters to pay higher taxes on the products in customs. Ministry determines the minimum value threshold per each kilogram of the imported product and sets forth that any exports into Turkey that does not meet this minimum value threshold shall be required to obtain a surveillance certificate. Based on new precedent, it is now possible to reclaim such overcharged tax and expenses.

Tax Investigators Trawl Through Panama Papers – Submitting a Voluntary Declaration

Tax investigators have apparently been sifting through the Panama Papers in the hope of rumbling suspected tax dodgers. There is still time to submit a voluntary declaration that can lead to immunity.

International Investments in Panama

Panama is a land blessed by God, where you can enjoy on the same day the tropical heat of its beaches and the fresh air from the high lands.

Property Purchase Taxes and Fiscal Benefits in Italy – Purchase of a Luxury Home

  By Luxury Law
When you purchase a property in Italy, you need to be aware of the amount of taxes you will be required to pay, and at that stage you need to be informed if you are purchasing a luxury home or not, this might make a huge difference, as a luxury home is excluded from “fiscal benefits”.

Taxation in Egypt

Tax system :As a result of enactment of the Tax Law 91 for the year 2005, and its amendment by the Presidential Decision No. 96 for the year 2015, the taxation system in Egypt has been transformed.

Enhanced Life Estate Deeds in Florida

Enhanced life estate deeds, commonly known as “Lady Bird Deeds” provide a legal mechanism for property to pass automatically to a person or group of people without going through Florida probate.

Tax Implications of Brexit

Leave or Remain? We will know the answer today! One can imagine that if UK leave the EU, the country is very likely to have their own tax and TP legislation. Facing the possible leave vote, MNCs may eager to determine the potential tax implications such as the absence of the EU Parent-Subsidiary Directive and the imposition of WHT on dividends.

Hong Kong still Takes the Lead in Corporate Treasury Centre – Analysis from Tax Perspective

The Singapore Government has recently announced in their budget that, the concessionary tax rate for corporate operations that qualify as Corporate Treasury Centre (CTC) would be 8%, decreased from 10%, and such move set the major tax rate to 0.25% lower than the level proposed by the Hong Kong Government as part of their CTC tax incentive measures which are still undergoing legislative process.

Invest in Hong Kong to capture Belt and Road opportunities

China is taking forward the Belt and Road initiative, the national strategy for long term development. It is certain that the emerging markets along the routes are likely to become the new catalyst for the future development of Hong Kong.

Implementation of BEPS Project in Hong Kong and its Implications on Transfer Pricing Rules

The Commissioner of Hong Kong Inland Revenue Department recently commented on the implementation of BEPS project in Hong Kong, particularly in the area of transfer pricing (TP). The Hong Kong Government regards TP legislation and TP documentation requirements are their top priority. The Commissioner also said that the simplified limitation on benefits (LOB) rule as well as the principle purposes test (PPT) will very likely be the norm for Hong Kong tax treaties in the coming future.

According to European Commission and Deloitte, Belgium is a Heaven for Business and Tax Immigration

  By Lexial
There is a Belgian paradox insofar as, every year, Belgium is ranked by OECD among the highest taxed countries, based on the ratio of the tax burden (state, regional and local taxes, social contributions) and gross domestic product; within the European Union, Belgium is also known for being the second country with the highest tax burden. But Deloitte and the European Commission refer to sophisticated mechanisms.

Inheritance Tax Reform Must be in Place by June 30, 2016 in Germany

The reforms to inheritance tax need to be in place by June 30, 2016, yet company heirs in particular still do not know what burdens they will be faced with going forward.

Double Tax Treaty between Cyprus and Latvia signed

The Republic of Cyprus and the Government of the Republic of Latvia signed in Brussels, on 24 May 2016, a Treaty for the Avoidance of Double Taxation on Income (‘DTT’).

Panama Papers – Voluntary Disclosure in Response to Tax Evasion in Germany

The so-called “Panama Papers” have the potential to reveal tax evasion on a massive scale. German tax evaders can return to a state of tax compliance by way of voluntary disclosure.

Cyprus – India Double Taxation Agreement “Concluded in Principle”

According to reports in the Indian media, the Cyprus foreign ministry has confirmed that the Cyprus authorities have informed their Indian counterparts that they are ready to finalise the new double taxation agreement between the two countries, having accepted in principle the Indian government’s proposed changes regarding the taxation of capital gains.

Taxes in Hungary: More than a Lot

According to [some] calculations there are presently 60 taxes in force in Hungary. Value added tax accounts for 25% of central tax revenues whereas the personal income tax accounts for 13%. However, most taxes account for less than 1% of these tax revenues. The figure of 60 different taxes seems slightly excessive also in an international context.

Home Underwater? Four Steps You Can Take to Improve Your Situation

Unfortunately, many people are still suffering from the housing market crash that began in 2006. It’s particularly painful if you owe more on your mortgage than your house is worth.

Innovative Employee Incentives – Are They at the Doorstep?

One of the most efficient ways to motivate employees is to make them owners. In Hungary, however, plenty of legal and tax obstacles have restricted the introduction of such incentive so far. Changes made to the legal and tax environment in the recent years may yet boost the spread of employee stock programmes in the future.

Amendments to the Cyprus Tax Laws to Promote Restructuring

ln December 2015 the Cyprus tax laws were amended to temporarily exempt loan restructurings from tax in order to facilitate and encourage the restructuring of non-performing loans. The amendments affect the lncome Тах Law, the Capital Gains Тах Law, the Special Defence Contribution Law, the Stamp Duty Law, the VAT Law, the Collection of Taxes Law and the Department of Lands and Surveys (Fees and Charges) Law.

Problems of filing reporting on controlled transactions in 2016 in Ukraine

According to the requirements of the Tax Code of Ukraine taxpayers, whose amount of controlled transactions with one counterparty exceeds 5 million USD (excluding VAT), are required to present the report on controlled operations for reporting calendar year to central executive body that implements the state tax and the customs policy, before May, 1 of the year following the reporting by electronic means electronically in compliance with the law on electronic document and digital signature.

International Forwarder is Not Responsible for a Delay in the Release of Goods Due to the Holiday Season in Isreal

We will review the case of a bicycle and electric vehicles importer ("the importer"), who hired the services of a forwarding and customs broker ("the forwarder"). The importer sued the forwarder for a delay in the release of goods from customs.

A Customs Debt Notice which Is Not Backed by Tangible Evidence May Be Annulled in Israel

The Tel Aviv Magistrate Court determined that an importer proved his claim regarding the essence of the goods and accepted the importer's classification. The court criticized the Customs Authority for its conduct in the case, as it failed to preserve samples of the product and submitted opinion reports based on theories and assumptions rather than facts.

Illicit Funds in Offshore Accounts: Avert Prosecution with Timely Voluntary Declaration in Germany

Hesse’s Finance Minister, Dr. Thomas Schäfer, has announced that the fight against tax evasion will continue. Voluntary disclosure is still the only way out for tax dodgers.

Declaring and Re-Declaring of Bulgarian Properties in the Local Municipality

Importance of declaring both of the spouses in the property declaration.

Agreement on the Avoidance of Double Taxation between Cyprus and Ethiopia

On the 30/12/2015, The Government of the Republic of Cyprus and the Government of the Federal Democratic Republic of Ethiopia have signed the Agreement on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income.

Scholz Holding GmbH: Deferred Payment of Interest

Investors in Scholz Holding GmbH bonds will not receive an interest payment on March 8. The due payment has been deferred until May 31, 2016.

Distant Trade in Ukraine of Non-resident Companies: Features of Tax Regulation

Remote trading in Ukraine is developing rapidly, created favorable conditions, therefore it would be reasonable it would be prudent for many companies of distant trade - non-residents to consider the Ukrainian market as one of the high-potential.

Untaxed Income from Capital in Foreign Accounts – Voluntary Disclosure in the EU

Be it Liechtenstein, Austria or Switzerland, many tax havens have had their day. Anyone who still has untaxed income in foreign accounts ought to consider voluntary disclosure.

The Payable Tax Under the Egyptian Law

Under the Egyptian law there are different taxes that shall be paid for different transactions, estates’ registration and income tax.

Tax Compliance Management Systems for Businesses in Germany

Complex tax legislation and changes to the rules can result in mistakes being made by businesses when it comes to tax matters. An efficient tax compliance management system helps to prevent mistakes and avoid sanctions.

Tax Evasion: Automatic Exchange of Information to Trigger New Wave of Voluntary Declarations - Germany

Anyone who has evaded taxes is still able to submit a voluntary declaration that can lead to immunity. With the help of a successful voluntary declaration, it is possible to avoid a conviction for tax evasion.

Time to Pay Attention to Anti-Dumping Petitions in Taiwan

Since December 2015, U.S. steel producers have filed cases charging foreign competitors with dumping products, U. S. government has twice penalized foreign steel producers as a result. Likewise, the Taiwan based steel manufacture, Chinese Steel Corporation (“CSC”), has filed a petition to the competent authority of Taiwan.

The Non-Operating Foreign Companies in Jordan

According to Jordanian Corporate law, the non-operating Foreign Company in Jordan is a Company or an entity which has its regional or representative office in Jordan for operations that it conducts outside the Kingdom for the purpose of using such a regional or representative office for managing its operations and coordinating them with its headquarters, and it is prohibited from carrying out any business or commercial activity inside the Kingdom.

Recovering Your Romanain Investment

Companies have been formed in the past for many reasons in Romania. Over the past few years the Romanian Trade Registry has endeavoured to clean up the number of Romanian dormant or non-trading companies which had been set up in the first flush of a free trade economy as shown on the register. In many cases the owners have let these companies die as they had no interest in them or their assets.

Value-Added Tax in Egypt

Value Added Tax (VAT) is the tax on the amount by which the value of an article/item has been increased at each stage of its production or distribution which means that taxes are applied to the difference between the seller-purchased price and the resale price. This is accomplished by taking full tax on all sales, but refunding the tax difference to the sellers.

What Happens If I Don’t Pay Taxes for Several Years?

  By HG.org
People may not pay taxes for a variety of reasons. They may think that they will not owe anything and the cost to prepare them will outweigh whatever small return they might receive. A recent divorce or death may make the process confusing. Someone may know that they will owe taxes and may try to avoid tax liability by simply not filing. Whatever the reason, the consequences for not filing taxes can be very serious.

What Tax Will You Pay On Company Incorporation in Romania

One of the current most challenging issues on the incorporation of a company in Romania is the immediate tax impact on the company and its profitability. The majority of Romanian companies were incorporated with the minimum capital of two hundred (200) RON. This means a minimum capital of approximately forty five (45) Euros. This is still the case.

Amendments to the Tax Legislation of Cyprus

New laws have recently been enacted in Cyprus, effecting important changes to the Income Tax Law and Capital Gains Tax Law. In addition, a serious change has been effected on the procedure followed by the Income Tax Authorities in issuing tax residency certificates with the aim to secure that the management and control of the tax resident companies is indeed exercised in Cyprus.

What Your Child Custody Arrangement Means for Your Tax Return

You may be ready to start your taxes. You’ve collected your W-2, 1099’s and other documents. You have last year’s tax form for guidance. But, if you’ve gotten divorced in the last year, this year’s taxes may be very different.

Hong Kong has Signed Double Tax Agreement with Russia

Hong Kong and Russia have entered into a Comprehensive Double Tax Agreement (“CDTA”) on Jan 18, 2016. This is the 34th CDTA that Hong Kong has signed with its trading partners. The CDTA sets out clearly the allocation of taxing rights between the two jurisdictions and thus will help investors better assess their potential tax liabilities from cross-border economic activities.

Stamp Tax on Transactions by Electronic Means in Buenos Aires

On January 1, 2015, Law No. 5493 entered into force, introducing amendments to the Tax Code of the Autonomous City of Buenos Aires (“TC”) concerning the Stamp Tax.

Boundaries of Allowed and Forbidden in Parallel Import in Israel

Parallel import in Israel is a growing and expanding phenomenon. Many brands are imported not only by official/exclusive importers, but by other importers as well.

Certificate of Origin under Trade Agreements - Prospects and Risks in Israel

Those who are engaged in the import of goods from countries with which Israel has entered into trade agreements, enjoy customs exemption on a regular basis, but are constantly exposed to the risk that such customs benefits will be revoked retroactively.

Israel Import Taxes: New Voluntary Disclosure Procedure

On September 7, 2014, the Israel Tax Authority published a new procedure for voluntary disclosure of previously unreported income and assets, as well as a temporary order to replace the previous procedure, which was in effect since 2005, and the temporary order, which was in effect since 2011.

Defense Export Supervision - Obtaining a Marketing License in Israel

At the end of 2007, the Defense Export Control Law, 2007 (hereinafter: the "Law") entered into effect.

Doing Business in Cote d’Ivoire: New Steps for a More Attractive Business Climate

On regional level, Cote d’Ivoire belongs to three major regional entities: The Economic Community of West African States (ECOWAS), The West-African economic and monetary Union (WAEMU). These countries share the same currency, the same central bank (BCEAO), and the same business law. The Organisation for the Harmonisation of Business Law in Africa (OHADA)

Doing Business in Cameroon: Key Issues to Be Aware Of

Cameroon is described as the largest economy of Central Africa because of its demographics (20 million), with an area of 475,442 km˛, and a diversified economy. As a state party to the Organisation for the Harmonisation of Business Law in Africa (OHADA) and the Economic and Monetary Community of Central Africa (CEMAC), Cameroon has adopted financial regulations enacted for the whole countries of CEMAC.

Landmark Case Confirms the Tax Exemption to the Internal Reorganization of an Economic Group in Argentina

On September 7th, 2015, the Federal Court in and for the City of Mar del Plata ruled in favor of the merger between business entities owned by the same economic group. Such decision was based on Law No. 20,628 about income tax (the “income tax law”), its regulatory decree, and precedents from the Argentine Supreme Court of Justice.

December 2015 Amendments to Cyprus Tax Laws

In July 2015 the Cyprus government submitted a number of draft laws to parliament to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax regime and make it more attractive, fair, and effective, with the aim of stimulating economic activity and attracting inward direct investment.

Hong Kong Strives for Becoming the Hub of Corporate Treasury Centres with Attractive Tax Incentives

Nowadays, owing to the growing importance of the Asian market, multinational corporations are encouraged to set up their corporate treasury centres (“CTC”) in the region.

Tax Evasion in Germany: Time Is Running Out for Voluntary Disclosure

Be it as a result of the purchase of CDs containing information on tax evaders or cooperation among countries, things are becoming increasingly difficult for tax evaders. Voluntary disclosure represents the only way out for them.

Import Duties in Bosnia and Herzegovina

Indirect Taxation Authority is responsible for the collection of all customs duties.

Tax Evasion in Germany: Investigators’ Nets Becoming Ever More Tightly Knit – Voluntary Disclosure Loophole

Whether it be untaxed illicit earnings or untaxed income from capital, tax evaders are taking a big risk. They can address the risk of being convicted with a voluntary declaration.

German Tax Evasion: Retroactive Group Inquiries Increase Risk of Detection – Voluntary Disclosure

Tax dodgers who have already closed their accounts with untaxed income from capital in Austria or Switzerland still need to worry about detection. Voluntary disclosure continues to present a way out.

Incorporation of a Cyprus Company – Legal Aspects and Advantages

The formation of a company in Cyprus is a simple and straightforward process and offers huge tax advantages.

Time Is Running Out for Concealed Untaxed Income from Capital in Germany – Voluntary Disclosure on Account of Tax Evasion

It is now almost impossible for untaxed income from capital in foreign accounts to remain concealed from the German exchequer. As long as the tax evasion has not yet been detected, a voluntary declaration can still be submitted.

Cyprus International Trust

A Trust is an arrangement whereby a person known as the ‘Settlor’ transfers ownership of property to another person or persons, the 'Trustees’ for them to hold on behalf of third persons, the ‘Beneficiaries’. The assets are placed under the control of the Trustees for the benefit of the beneficiaries or for a specified purpose.

China’s “One Belt One Road” Provides Catalyst for Hong Kong Taxation Reform

According to the China central government’s 13th five-year plan, it has showed its full support for Hong Kong to participate in the nation's "One Belt One Road" development strategy, in which Hong Kong is going to play a bigger role in China's opening up to the rest of the world.

Voluntary Disclosure Is the Only Solution to Tax Evasion in Germany

Ever since the first CD on tax evaders was purchased in 2006, the number of voluntary declarations concerning tax evasion has risen dramatically. This remains the only way of returning to a state of tax compliance.

VAT Registration of Bulgarian Businesses

Bulgarian businesses are subject to VAT registration under specific rules. A brief overview of the requirements for a VAT registration in Bulgaria.

Luxembourg is Deleted from the Map of Hungary

The recent amendment of the Luxembourg - Hungary double tax treaty will result in a sharp decrease of Luxembourg-based schemes for Hungarian real estate transactions. Those groups which currently use such schemes for holding their Hungarian real estates will need to react fast.

Tax Evasion in Germany: Illicit Earnings In Foreign Accounts – Solution Is Voluntary Disclosure

Voluntary declarations with respect to tax evasion have not come to an end this year, which indicates that untaxed income in foreign bank accounts is becoming a burden on those concerned.

Why You Should Not Represent Yourself in an IRS Audit

Representing yourself or your company in an audit initiated by the Internal Revenue Service (“IRS”) is likely to be an exercise in futility. The IRS employs highly skilled revenue agents who will seek to take advantage of taxpayers who, understandably, are not knowledgeable on the rights and powers of the IRS.

Coming Out of the Shadows: IRS’s OVDP and Streamlined Disclosure Programs

In part because of the high levels of noncompliance with foreign tax reporting requirements (oftentimes out of innocent ignorance), the IRS has developed voluntary disclosure programs that allow taxpayers to come forward, correct their past mistakes, pay past-due taxes, and pay a set penalty (or, in some circumstances, pay no penalty).

Enforced Tax Collections: IRS’s Power of Lien and Levy

The IRS collection process is a series of actions that the IRS can take to collect taxes that taxpayers owe if they do not voluntarily pay them. Generally, a taxpayer is required to pay a tax along with filing a tax return. The IRS will assess a taxpayer’s delinquent tax obligation if the taxpayer fails to pay a tax obligation when due. Subsequently, the IRS will send a notice and demand for payment to the taxpayer.

Cyprus International Trusts Overview

Cyprus International Trusts feature essential regulatory, confidentiality and tax advantages, providing interested settlors and beneficiaries with unparalleled tax planning possibilities and an estate planning solution of impeccable quality.

Release of OECD Action Plan on BEPS Final Report and its Tax Implications to China and Hong Kong

On 5 October 2015, the Organisation for Economic Cooperation and Development (OECD) issued a final report with regards to its Action Plan to address Base Erosion and Profit Shifting (BEPS), as well as a plan for follow-up work and a timetable for implementation. In this article, we shall focus on the action plan regarding transfer pricing (TP) and its tax implications to China and Hong Kong.

Non-Profit Foundations Based in Switzerland Have to Pay Tax on Income Generated in Germany

Foundations based in Switzerland need to pay tax on their income generated in Germany, even if they pursue non-profit causes.

Errors that Can Lead to Raider Seizure in the Ukraine

Today it is not a secret that the "raider / unlawful seizures" have become the norm and rather the rule of doing business than the exception to the rule, and both domestic enterprises and large foreign investors are suffering from unlawful seizures. What can be attributed to the notion of "raider seizure". Raider seizure - unlawful seizure of real estate, corporate law, intellectual property by other economic entities, physical entities and public authorities.

Italians Can Derive Tax Benefits from the Newly Enforced Double Tax Treaty with HK when Investing in China

The agreement between Hong Kong and Italy for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion has entered into force.

Tax Implications for Thai Companies Hiring Services Overseas

When a Thai company engages the services of another company, it must comply with a few tax obligations under the Revenue Code. It must withhold and remit a tax of 3% of any fees paid for services, it must itself pay a value-added tax of 7% on those fees, and the contract as well may be subject to a stamp duty depending on the transaction. But what are the implications for a Thai company that engages the services of a company overseas?

New Resolution Imposes the Electronic Billing System to Contributors Registered in the Value-Added Tax - Argentina

On March 11, 2015, the Tax Authorities (hereinafter “AFIP”) issued General Resolution No. 3749/2015 (“GR”) which obliges contributors registered in the Value-Added Tax (from now on “VAT”) to apply the electronic invoices’ system to support operations within the framework of the internal market, having to comply since July 1st of this year.

Time-Series Comparison Only Permissible as Method of Estimation Under Certain Conditions in Germany

The tax authorities are increasingly applying time-series comparisons as a method of estimation in the context of external audits, but according to the Bundesfinanzhof (German Federal Fiscal Court), this is only permissible under certain conditions.

Conclusion of a Protocol that Will Amend the Double Tax Convention between Cyprus and Ukraine

The Ministry of Finance of Cyprus announced on 08 September 2015 the conclusion of the negotiations with Ukrainian Ministry of Finance. The two Contracting States agreed to a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income when it expire.

Inherited IRAs & the Taxes Involved

Receiving an inheritance can be a blessing, but there are typically tax obligations involved including the inheritance of an IRA. If you inherit an IRA, you should check with an attorney or financial advisor as soon as possible to find out what your options are.

Cyprus and Iran - New Double Tax Treaty

During a recent visit of a senior Iranian delegation to Cyprus, the Cyprus-Iran DTT was signed. The DTT is yet to be ratified or come into force, a fact that is expected to happen in the next few months.

EU Planning Tax Reforms

The European Union wants to change its tax policy. One of its aims is for businesses in future to pay tax on their profits in the state in which they are generated.

Hong Kong Becomes More Investment Friendly after Tax Exemption

On 17 July 2015, the Hong Kong Government gazetted the Inland Revenue (Amendment) (No.2) Ordinance 2015 (“the Ordinance”), which extended the profits tax exemption for offshore funds to private equity (“PE”) funds.

Tax Implications Of Asset Transfers

Depending on the extent of a couple’s assets, a divorce can raise some very complicated financial questions.

Introduction of GST Bill in India May Be Delayed

The much awaited indirect tax reform in India will be further delayed.

Criminal Charges for Issuing a Bad Electronic Funds Transfer

A new law went into effect in New Jersey last year, which makes it a criminal offense to issue a bad electronic funds transfer.

The Latest Development and Tax Issues of Islamic Bond Market in Hong Kong

Islamic finance is one of the fastest growing sectors in the international financial market. Given the strategic importance and influence of the Middle East investors, Islamic finance is increasingly in demand by investors wanting investment and financing products compliant with Islamic law (known as “Shariah”).

Cyprus Proposed Tax Reforms: Interantional Business Center Credentials Reaffirmed

On July 1, 2015, the President of Cyprus forwarded several proposed tax law amendments to the Cyprus Parliament for ratification. Provided the parliament enacts them into law which is a certainty they will take effect upon publication in the Official Gazette of Cyprus.

Tax Effects of the Dissolution of Companies in Panama

Article 528-A of the Commercial Code, added by Act 85 of 2012, deals with the dissolution of companies and explains causes and effects of their permanence in time to the end of the liquidation of its assets, after collecting their debt and pay its liabilities.

Tax Deductability of Bribes in Greece

The prohibition of tax deductibility of bribes and the risk of claiming these payments as "expenses" in order to get a tax return under the Greek law.

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