Mauritius Double Avoidance Taxation Treaties A comparative Analysis.

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Mauritius Double Avoidance Taxation Treaties A comparative Analysis."

Transcription

1 Mauritius Double Avoidance Taxation Treaties A comparative Analysis. Contents 1 Scope of analysis 1.1 Double tax treaties under review 1.2 Articles under review 2 Summary of Mauritius tax law and Luxembourg tax law 2.1 Mauritius income tax law 2.2 Luxembourg income tax law Taxation of dividends Taxation of interests Taxation of royalties Taxation of capital gains Investment funds in Luxembourg 3 Analysis of the DTTs 3.1 Luxembourg - Mauritius DTT Dividends Interests Royalties Capital gains Relevant issue 3.2 Mauritius - India and Mauritius - Malaysia Dividends Interest / Royalties / Capital gains 3.3 Mauritius - EU countries DTTs UK France Italy Germany 3.4 Mauritius - non-eu countries DTTs Singapore China Indonesia South Africa 4 Conclusion

2 1 Scope of analysis 1.1 Double tax treaties under review We have analysed the double tax treaties (hereinafter "DTT") provided to us, which are as follows: Mauritius - Luxembourg Mauritius Singapore Mauritius - China Mauritius Indonesia Mauritius India Mauritius - Malaysia Mauritius - South Africa Mauritius - UK Mauritius - France Mauritius - Italy Mauritius - Germany In order to make an efficient analysis of those DTTs, we have made a comparison with DTT concluded with Luxembourg. Luxembourg has concluded DTT with all countries forming part of the European Union. Except for India and Malaysia, Luxembourg has concluded DTT with all the countries being part of the analysis. \ 1.2 Articles under review A structure of investment is generally implemented when dividends, interests, royalties and capital gains may be repatriated to the investors at an acceptable and efficient tax rate. We have consequently analysed the articles of the DTTs, which concern the dividends (generally article 10), the interests (generally article 11), the royalties (generally article 12) and the capital gains (generally article 13). To complete the analysis of such articles, reference has necessarily been made to the articles, which concern the elimination of double taxation (generally article 23).

3 Report Mauritius DTT modified.doc - 14 August 2002 In addition, the governments of the two countries concerned have sometimes signed a protocol forming part of the DTT. Generally, protocols grant a more favourable regime than the one agreed in the original DTT, especially in terms of dividends, interests and capital gains.

4 Summary of Mauritius tax law and Luxembourg tax law Basically, we have analyzed the advantages the DTTs concluded by Mauritius and by Luxembourg could provide. It should be noted that in specific cases, the domestic law could be more advantageous. As a general principle, DTTs cannot create a tax, which is not provided by the domestic law of the contracting States. Consequently, Luxembourg law applies whenever it provides for a more advantageous tax regime than the DTT. We have assumed this principle is of application in Mauritius. We will consequently give a brief summary of the Mauritian law and the Luxembourg tax law, especially in terms of dividends, interests, royalties and capital gains. 2.1 Mauritius income tax law In general, companies carrying on business in Mauritius are subject to tax on local and foreign source income. The rate applicable to those companies is 25%. There are no capital gains taxes in Mauritius. There are no withholding taxes: on dividends paid to a resident or a non-resident; on interests paid by an offshore company to non-residents or by a Mauritius bank to a non-resident bank (other companies to non-resident companies: 25%); on royalties paid by an offshore company to non-residents (other companies to nonresident companies: 25%). on capital gains; There are tax incentive companies, which enjoy a tax rate of 15%. These are called Category 1 Global Business license (hereafter "GBL1"). We understand that those companies may benefit from the double tax treaties, which

5 A GBL1 company is entitled to claim tax credit relief for the foreign tax withheld on the foreign source income against Mauritius tax. The foreign tax credit, which is allowed will be either the amount of foreign tax which has been charged and supported by written evidence; or in the absence of written evidence showing the amount of foreign tax charged, the amount of foreign tax will be presumed to be equal to 90% (80% as from 2003) of the Mauritius tax chargeable. The maximum credit is the lower of the actual amount of foreign tax withheld or 80% of the Mauritius tax. In the case of a dividend being paid to a GBL1 company holding at least 5% of the share capital of the company paying the dividend, tax credit can also be claimed on the foreign tax charged on the income out of which the dividend was paid i.e. the underlying tax. The relief for foreign tax is claimed when computing the annual tax of the company. Dividends received by an offshore company are tax free. 2.2 Luxembourg income tax law Taxation of dividends Taxation of dividends received Dividends received by a Luxembourg company that do not qualify for participation exemption are taxed at full corporation tax rate (i.e. 30,38%). Those dividends can however be 50% exempt (i.e. subject to a 15% effective tax rate) if they are paid by: a fully taxable resident company with a share capital; a foreign company with a share capital that is subject to a tax comparable to Luxembourg income tax (i.e. at least 15% applied on a similar basis) and that resides in a treaty country; an EU company in the sense of the parent-subsidiary directive, i.e. subject to corporate income tax rate (not necessarily at a rate comparable to Luxembourg corporate income tax rate). When the company qualifies for participation exemption, dividends may be exempt if the subsidiary that pays the dividends is a fully taxable resident company with a share capital, or an EU subsidiary in the sense of the parentsubsidiary directive, or a foreign subsidiary subject to an income tax rate comparable to Luxembourg corporate income tax on a similar basis, in practice generally an effective minimum income tax of 15%. The Luxembourg company must hold at least 10% of the share capital of the subsidiary or the acquisition price must be of a minimum of There is also minimum detention period of 12 months at the date at which the dividend is allocated or the company commits to hold the minimum shareholding for an uninterrupted period of 12 months at least. Report Mauritius DTT modified.doc - 14 August 2002

6 Taxation of dividends paid Generally, dividends paid by a Luxembourg company are subject to a withholding tax of 20%. There is no withholding on dividends distributed by a fully taxable Luxembourg company if the recipient is a fully taxable resident company with a share capital, a Luxembourg branch of company resident in another EU member State or in a treaty country, or an EU subsidiary in the sense of the parent-subsidiary directive. The Luxembourg company must hold at least 10% of the share capital of the subsidiary or the acquisition price must be of a minimum of There is also a minimum detention period of 12 months at the date at which the dividend is allocated Taxation of interests Interests received by a Luxembourg company are taxed at normal corporate tax rate, i.e %. Interests paid by a Luxembourg company are not subject to a withholding tax Taxation of royalties Royalties paid by a Luxembourg company are subject to a withholding tax of 10%. Royalties received by a Luxembourg company are included in the taxable basis of the company and are taxed at normal corporate income tax rate, i.e % Taxation of capital gains Capital gains realized by a company, which do not qualify for participation exemption are taxed at normal corporate income tax rate, i.e %. Capital gains realized by a company, which qualify for participation exemption are exempted from corporate income tax in Luxembourg. The subsidiary should be a fully taxable resident company with a share capital, or an EU subsidiary in the sense of the parent-subsidiary directive, or a foreign subsidiary subject to an income tax rate comparable to Luxembourg corporate income tax on a similar basis, in practice generally an effective minimum income tax of 15%. The Luxembourg Company must hold at least 10% of the share capital of the subsidiary or the acquisition price must be of a minimum of There is also minimum detention period of 12 months at the date at which the capital gain is realized or the company commits to hold the minimum shareholding for an uninterrupted period of 12 months at least.

7 2.2.5 Investment funds in Luxembourg In the course of recent years Luxembourg has established a leading position throughout Europe as a location for international investment funds. Significant factors in this success were EU directives liberalising the marketing of investment funds. In the past decade Luxembourg has extended its reputation as a location for investment funds beyond European borders in developing a range of highly competitive services in connection with the management of investment funds. The Luxembourg legislation is very flexible as regards to the legal form of the funds. Luxembourg funds can be set up as mutual funds or as investment companies with fixed or variable capital. Mutual funds do not have legal personality themselves and are accordingly not subject to Luxembourg income or net worth tax. Although investment companies operating as public limited companies with fixed or variable capital are basically resident taxpayers, they are specifically exempt from income and net worth tax. Foreign investors are not subject to income tax in Luxembourg. There is no withholding tax on distributions paid by investment funds. Investment funds are subject to only two taxes: contribution tax (flat amount of approx. 1,250) and an annual subscription tax (generally 0.06% on net assets and 0.01% on net assets for private investment funds). The ECOFIN Counsel has adopted a new directive on investment funds (so-called UCUS III) on March 4, The directive aims at extending the scale of products in which mutual funds may invest. Particularly, the directive allows a fund to invest in another funds so as to constitute structures called "funds of funds". Luxembourg investment funds used to have a Mauritian subsidiary to invest in India so as to benefit from the Mauritius-India DTT. The directive UCITS III has modified the rules regarding the detention of a subsidiary by an investment fund so that the structure of investment to India via Mauritius cannot exist anymore as such. The structure "funds of funds" may be a good alternative as a Luxembourg investment fund may invest in another fund located in Mauritius, which would invest in India so that the benefit from the double tax treaties is still efficient. Report Mauritius DTT rnodified.doc - 14 August 2002

8 In our opinion Mauritian authorities might take advantage out of the development of an investment funds platform in Mauritius, under the condition that these Funds would be treaty protected. Analysis of the DTTs In the present section, we have indicated possible structures to be implemented. Those are not exhaustive; many structures could be envisaged taking advantages of DTTs Mauritius has concluded. Please bear in mind that Luxembourg domestic law should generally be applied each time it is more advantageous than the DTT. We assume the same applies in Mauritius. 3.1 Luxembourg - Mauritius DTT Dividends From a Luxembourg point of view, the DTT is advantageous as dividends paid by a Luxembourg company to a Mauritius company cannot benefit from the Luxembourg participation exemption and are consequently subject to the Luxembourg WHT of 20%. By application of the DTT, the WHT on dividends distributed by a Luxembourg company to a Mauritius company may be reduced to 10% or 5%, instead of 20% as foreseen in domestic law. From a Mauritius point of view, the Mauritius domestic tax law is more advantageous than the DTT, as there is no withholding tax on dividends paid by a Mauritian company to a Luxembourg company. Furthermore, if the Luxembourg participation exemption applies, the dividend income is tax exempt in Luxembourg Interests From a Luxembourg point of view, the DTT does not grant more benefits

9 than the domestic law, since there is no withholding tax on interest paid by a Luxembourg company to resident and non-resident companies. From a Mauritian point of view, the DTT can be advantageous when the Mauritian company, paying interests to a Luxembourg company is not an offshore company or a bank.

10 3.1.3 Royalties The DTT provides for no WHT on royalties paid (Luxembourg domestic tax law provides for a WHT of 10% on royalties) Capital gains The DTT does not grant more benefits than the domestic law, since there is nc withholding tax on capital gains realized on the sale of a Luxembourg or a Mauritius company. In a structure where a Mauritius parent company sells a Luxembourg company, there would be no WHT tax in Luxembourg and capital gains would be tax exempt in Mauritius. In a structure where a Luxembourg parent company sells a Mauritius company, there would be no WHT tax in Mauritius and capital gains would be tax exempt in Luxembourg in case the Luxembourg participation exemption applies Relevant issue Basically, all the benefits, which follow the application of the DTT and of the Luxembourg participation exemption will only be granted by the Luxembourg tax authorities if the Mauritian company is effectively taxed at a rate exceeding 15%. This point is particularly relevant in Luxembourg when applying the Luxembourg participation exemption. For the exemption of dividends, capital gains and liquidation proceeds received by a Luxembourg company, the foreign subsidiary must be subject to an effective minimum income tax rate of 15%. A GBL1 company is entitled to claim as tax credit the amount of foreign tax which has been charged, provided the foreign tax paid can be supported by written evidence. This situation does not raise any issue in Luxembourg as it can be proved that the income received by the Luxembourg company has already been subject to tax (at least 15%) in the foreign country. In the absence of written evidence showing the amount of foreign tax charged, the amount of foreign tax will be presumed to be equal to 90% (80% as from 2003) of the Mauritius tax chargeable. In that case, the effective income tax rate is 1,5% (3% as from 2003). From a Luxembourg point of view, this 1.5 % (or 3%) effective tax rate might give raise to an issue, and the Luxembourg tax authorities might challenge the application of the Luxembourg participation exemption. However please note that the validity of a Luxembourg-Mauritius structure should be appreciated on a case-by-case basis, as different elements should be taken into account.

11 Mauritius - India and Mauritius - Malaysia The Mauritian treaty network as under review includes two treaties with countries that have not concluded a treaty with Luxembourg. Li case of a structure implying a Luxembourg company and an Indian company or a Malaysian company, reference should be made to the domestic tax law of each country in order to determine the tax regime applicable on income flows. This might bring a very high tax burden. It may consequently be interesting to insert for instance a Mauritian company between a Luxembourg company and an Indian company so as to benefit from the advantages provided by the DTTs signed by Mauritius with India. Advantages should however be compared with the domestic tax law of India, which may provide for lower tax rates than the DTTs. Dividends We understand that Indian domestic tax law does not currently provide for any withholding tax on dividend distribution. Only an additional income tax of 10,2% would be due by the company paying the dividends. This tax regime is about to change and the new tax regime on dividends will provide for a withholding tax of 20%. Dividends distributed by an Indian subsidiary to its Luxembourg parent company should consequently be subject to a WHT tax of 20% in the next future. If the investment structure includes a Mauritius company, the global WHT rate should amount to 5% (India-Mauritius DTT: 5% (minimum shareholding of 10%) + Mauritius-Luxembourg: 0% (domestic law)). For comments on structures involving investment funds, please see section If an Indian company holds a Luxembourg company, dividends distributed will be subject to a WHT of 20%. If the investment structure includes a Mauritian company, the global WHT will amount to 5% (Luxembourg-Mauritius: 5% (if minimum shareholding of 10%) + 0% (domestic law)).

12 3.2.2 Interest / Royalties / Capital gains The Mauritius-India DTT could be interesting in terms of interest if a Mauritius bank grants a loan to its Indian subsidiary. In that case, there is no withholding tax on interests paid by an Indian company to a Mauritius bank. There is also no WHT on repatriation to the Luxembourg parent company of the Mauritius bank. The combination of the Mauritius-India DTT and the Mauritius-Luxembourg DTT allows a tax protection on capital gains. In a structure where a Luxembourg parent company holds a Mauritius company, which holds an Indian company, there will be no WHT on the sale of the Indian company (art 13 Mauritius-India DTT) and capital gains are not taxed in Mauritius (domestic law). Gains could be repatriated in Luxembourg through dividends without any WHT (Mauritius domestic law). 3.3 Mauritius - EU countries DTTs Basically, DTTs Mauritius has concluded with some EU countries seem to be more competitive than those concluded by Luxembourg with the same EU countries. DTTs Luxembourg has concluded with the UK, France, Italy and Germany have been in force for many years and since the Parent-Subsidiary Directive has been in force, the relationships between EU countries (and Luxembourg) are often more favourable than the DTTs concluded between EU countries and Mauritius. Consequently, we will not make any comparative analysis of EU DTTs Mauritius and Luxembourg have concluded, but only an analysis of the relevant elements of the Mauritius -EU countries DTTs. As Mauritius disposes of an efficient treaty network with Asia and Africa, EU countries could use Mauritius as a gateway to Asia and Africa UK For dividends distributed by a Mauritius company to its UK parent, the DTT provides for a WHT of 10% or 15% but there is no Mauritius WHT according to domestic tax law. The DTT is interesting when a Mauritius company pays interest to a UK bank, as there is no WHT. According to domestic tax law, there is no WHT only if an offshore company pays interest. The DTT reduces the WHT on royalties from 25% to 15% when the payer is a fully taxable Mauritius company.

13 3.3.2 France Same comments as above apply Italy Same comments as above apply Germany Same comments as above apply. 3.4 Mauritius - non-eu countries DTTs We have not analysed the domestic laws of Singapore, China, Indonesia and Soutl Africa. Please note that those domestic laws might provide for a more favourable taj regime on dividend, interest, royalties, and capital gains. Basically, DTTs Luxembourg has concluded with Singapore, China, Indonesia and Soutl Africa are less competitive than those Mauritius has concluded with the same countries. The interposition of a Mauritius Company between a company resident in the countries mentioned above and a Luxembourg company will generally reduce the WHT rates or dividend, interest and royalties Singapore The combination of the Mauritius-Singapore DTT and the Luxembourg- Singapore DTT is very efficient as there should be no WHT on dividend, interest and royalties paid. This is the case in a structure involving a Mauritius company interposed between the Luxembourg parent company and its Singapore subsidiary. Basically, dividends paid by the Singapore subsidiary to its Luxembourg parent company would be subject to a WHT of 5% (minimum participation of 10%) or 10% in other cases. If a Mauritius company is interposed, there will be no WHT (i.e. Singapore-Mauritius: 0% (DTT) + Mauritius-Luxembourg: 0% (domestic law)). The same argument applies for interest and royalties. With no Mauritius Company, interest and royalties paid by a Singapore subsidiary to its Luxembourg parent would be subject to a WHT of 10% (DTT). With the interposition of a Mauritius company, there is no WHT at all (Singapore-Mauritius: 0% (DTT) + Mauritius-Luxembourg: 0% (DTT)).

14 3.4.2 China The combination of the Mauritius-China DTT and the Luxembourg-China DTT could be interesting with respect to bank operations. If a Luxembourg bank grants a loan directly to a Chinese company, interest paid to the Luxembourg bank will be subject to a WHT of 10%. If a Mauritius bank is interposed between the bank and the company, there will be no WHT on interest paid (China-Mauritius Bank: 0% (DTT) + Mauritius bank-luxembourg bank: 0% (DTT)). As regards DTTs China has concluded with different countries, none of them include Hong Kong in their dispositions. Negotiations with Chinese authorities to modify the Mauritius-China DTT and to include Hong-Kong may provide Mauritius important competitive advantages Indonesia The interposition of a Mauritius company between a Luxembourg company and an Indonesian company may also be of use in the banking sector. The same structure as for China may document this South Africa There is no real advantage / disadvantage to combine the Mauritius-South Africa DTT and the Luxembourg-South Africa DTT, as both provide for the same tax regime: 5% or 15% WHT on dividends and no WHT on interest and royalties.

15 4 Conclusion Generally speaking, Mauritius has a very interesting and competitive DTT network, no only in comparison with Luxembourg DTTs. Structures contemplated in the presen report may also be used with other EU countries (as an alternative for Luxembourg) provided CFC rules are taken into consideration. In most of the structures we would however suggest to implement a Luxembourg holding company as an attractive investment centre. Its central situation within Europe, its political and social stability, good transport and communication links with other financial centres in Europe and its liberal attitude towards foreign capital inflow make Luxembourg the ideal place for a holding company. Most of the US conglomerates use a Luxembourg holding company in their investment structure. From that point of view, a Luxembourg holding - Mauritius company structure could be used as a gateway from the USA to Asia and Africa. In such a structure, Luxembourg could also be used as a holding of European companies together with a parallel structure with Asian and African countries via Mauritius. DTTs Mauritius has concluded with Asia are competitive. In that way, we would advise to develop DTTs with other Asian countries or extend the existing ones (e.g. to extend the DTT concluded with China to Hong Kong). Apart from the advantages of the DTTs concluded by Mauritius, the domestic law provides for very interesting elements. The tax credit system is an attractive provision of the Mauritius law for investors. The performance of all Luxembourg-Mauritius structures involving the Mauritian tax credit system should however be analysed on a case-by-case basis. The Luxembourg tax authorities would generally allow the application of the Luxembourg participation exemption if the Mauritian subsidiary is subject to tax of at least 15%. As the tax credit system in case of no underlying tax results in an effective tax rate of 3 to 4%, we would suggest verifying on a case-by-case basis with the Luxembourg tax authorities whether the contemplated structure does not raise any issue with regard to the application of the Luxembourg participation exemption. Mauritius might change some provisions of its domestic law in order to be even more attractive. Following the implementation of the new European directive UCITS III on investment funds, we would advise Mauritius to develop its legislation on investment funds so as to make them more attractive.

16 Mauritius used to be very attractive for Luxembourg investment funds wishing to invesl in India. The new directive UCITS III does not allow the Mauritian structure with a Mauritius company held by a Luxembourg investment fund anymore. This directive however includes the concept "funds of funds". The development of the Mauritius domestic law on investment funds and the protection of investment funds under treaty provisions would secure the transactions and consequently attract foreign investors in Mauritius.

UNIQUE TAX INCENTIVES in BELGIUM

UNIQUE TAX INCENTIVES in BELGIUM Federal Public Service Finance UNIQUE TAX INCENTIVES in BELGIUM 2014 Fiscal Department for Foreign Investments 25 22,3 23 24,2 26,3 25,1 28,2 31 31,3 34 34,3 37,1 37,9 36,5 38,6 40,1 2 Effective (Average)

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection

More information

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015 The Advantages of the UK as a Location for a Holding Company David Gibbs May 2015 The UK is an attractive location to site an international holding company since not only does it offer a relatively stable

More information

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Eric van Aalst Mark Riedy Citco Corporate Services Inc. Andrews Kurth LLP 450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Structuring International Operations

More information

Belgium in international tax planning

Belgium in international tax planning Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustrated

More information

The Use of the UK Holding Company in International Tax Planning

The Use of the UK Holding Company in International Tax Planning FACT SHEET The Use of the UK Holding Company in International Tax Planning Introduction The UK is considered by many professional tax planners to be a tax haven for non-uk nationals, and the best kept

More information

The UK as a holding company location

The UK as a holding company location The UK as a holding company location Tax May 2013 kpmg.com A key ambition is to create the most competitive tax system in the G20. As well as lowering tax rates, the Government wants to make the UK the

More information

Malta launches patents exemption

Malta launches patents exemption Malta launches patents exemption Background The Maltese government published regulations for the application of an exemption from corporate tax on royalties (and similar income) derived from qualifying

More information

Higher standards...making a difference for you. Withholding Tax

Higher standards...making a difference for you. Withholding Tax Withholding Tax The Indian Constitution has empowered only the Central Government to levy and collect taxes. Every person whose total income exceeds the maximum exemption limit shall be chargeable to the

More information

The Company Tax System in Malta

The Company Tax System in Malta The Company Tax System in Malta Maltese companies are subject to tax at 35% Malta s tax system adopts a full imputation system Effective system for relief of double taxation Compliant with EU law Maltese

More information

Malta Companies in International Tax Structuring February 2015

Malta Companies in International Tax Structuring February 2015 INFORMATION SHEET No. 126 Malta in International Tax Structuring February 2015 Introduction Malta is a reputable EU business and financial centre with an attractive tax regime and sound legislative framework.

More information

TAXATION AND FOREIGN EXCHANGE

TAXATION AND FOREIGN EXCHANGE 1. TAXATION OF SECURITY HOLDERS The taxation of income and capital gains of holders of H Shares is subject to the laws and practices of the PRC and of jurisdictions in which holders of H Shares are resident

More information

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 i Tel +31 I. (0)88 Introduction 2001300 Cell +31 (0)6 M The Netherlands is an attractive and advantageous

More information

Luxembourg holding companies: competitive and tax-efficient

Luxembourg holding companies: competitive and tax-efficient Luxembourg holding companies: competitive and tax-efficient June 2009 Table of contents 1. Introduction...3 2. Standard holding company (SOPARFI)...3 3. Double taxation treaties...3 4. Registration taxes...3

More information

An Introduction to Taxation in Indonesia. November 2012 Steven Solomon

An Introduction to Taxation in Indonesia. November 2012 Steven Solomon An Introduction to Taxation in Indonesia November 2012 Steven Solomon Contents 1. Introduction 2. Key facts about the Indonesia tax system 3. Investing in Indonesia 4. Trading with Indonesia 5. Using the

More information

Sri Lanka Tax Profile

Sri Lanka Tax Profile Sri Lanka Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: September 2014 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation

More information

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income.

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income. Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl

More information

May 18, Holding Companies for China Investments Are they still relevant?

May 18, Holding Companies for China Investments Are they still relevant? May 18, 2016 Holding Companies for China Investments Are they still relevant? Panama Papers Page 1 What are Offshore Companies? The term offshore company or offshore corporation is: a corporation or (sometimes)

More information

Company Formation in Austria. Tax l Accounting l Audit l Advisory

Company Formation in Austria. Tax l Accounting l Audit l Advisory Tax l Accounting l Audit l Advisory Company Formation in Austria When considering an investment abroad thought must be given to taxation of income received as dividends and interest as well as any capital

More information

THE ISRAELI TAX SYSTEM. Iris Stark, CPA

THE ISRAELI TAX SYSTEM. Iris Stark, CPA THE ISRAELI TAX SYSTEM Iris Stark, CPA October 2012 THE ISRAELI TAX SYSTEM Taxation in Israel is based on an individual method. Accordingly, as of 2003, all Israeli residents are liable for payment of

More information

Ireland Country Profile

Ireland Country Profile Ireland Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Ireland EU Member State Yes Double Tax Treaties With: Albania Armenia Australia

More information

Holding companies in Ireland

Holding companies in Ireland Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation

More information

Greece Country Profile

Greece Country Profile Greece Country Profile EU Tax Centre March 2013 Key factors for efficient cross-border tax planning involving Greece EU Member State Double Tax Treaties With: Albania Estonia Lithuania Serbia Armenia Finland

More information

Taxation. 1. Individual Taxation in Malta

Taxation. 1. Individual Taxation in Malta Taxation The combination of Malta s tax system and its extensive double tax treaty network (over 50) means that, with proper planning and structuring, investors can achieve considerable fiscal efficiency

More information

The Maltese Corporate Tax System.

The Maltese Corporate Tax System. The Maltese Corporate Tax System. Brief Information on: Integrated Imputation System Tax Accounts Participation Exemption Double taxation relief Refunds of Malta tax paid No outbound withholding taxes

More information

Foreign Tax Credits - Article 23 of DTAAs

Foreign Tax Credits - Article 23 of DTAAs Foreign Tax Credits - Article 23 of DTAAs CA Shabbir Motorwala WIRC-ICAI : Beginners Study Course on International Taxation 4 July 2015 Types of Double Taxation Contents Elimination of Double Taxation

More information

TAXATION AND FOREIGN EXCHANGE

TAXATION AND FOREIGN EXCHANGE TAXATION OF EQUITY HOLDERS The following is a summary of certain PRC and Hong Kong tax consequences of the ownership of H Shares by an investor that purchases such H Shares in the Global Offering and holds

More information

BLUM Attorneys at Law

BLUM Attorneys at Law BLUM Attorneys at Law CORPORATE TAXATION SYSTEM IN SWITZERLAND Outline of Swiss Corporate Tax System Levels of Taxation in Switzerland Resident companies are subject to: federal corporate income tax, and

More information

MALTA Jurisdictional Guide

MALTA Jurisdictional Guide MALTA Jurisdictional Guide GENERAL INFORMATION The Republic of Malta is situated in the centre of the Mediterranean, south of Sicily, east of Tunisia and north of Libya. Malta gained its independence from

More information

Private Company: SWEDEN

Private Company: SWEDEN Private Company: SWEDEN Limited Liability Company [Aktiebolag /AB] Partnership [Handelsbolag / HB] Limited Partnership [Kommanditbolag / KB] Formation and Registration Bank Accounts Professional Administration

More information

Taxation. General. 1. Taxation UK. Mondi plc Ordinary Shareholders

Taxation. General. 1. Taxation UK. Mondi plc Ordinary Shareholders Taxation The statements set out below are intended only as a general guide to United Kingdom ( UK ) and South Africa ( SA ) current law and practice and apply only to certain categories of person who are

More information

Incorporating International Tax Laws in Multinational Capital Budgeting

Incorporating International Tax Laws in Multinational Capital Budgeting APPENDIX 14 Incorporating International Tax Laws in Multinational Capital Budgeting Tax laws can vary among countries in many ways, but any type of tax causes an MNC s after-tax cash flows to differ from

More information

Standard Chartered Publicised tax avoidance strategy

Standard Chartered Publicised tax avoidance strategy Standard Chartered Publicised tax avoidance strategy Summary Standard Chartered is a UK FTSE-100 listed bank with an extensive presence across Africa, Asia and the Middle East. The bank offers a wide-range

More information

CZECH AND SLOVAK COMPANIES WITHIN INTERNATIONAL TAX PLANNING STRUCTURES. PROTTECO TRUST COMPANY LTD ing. Tomáš Chrobák Executive Manager

CZECH AND SLOVAK COMPANIES WITHIN INTERNATIONAL TAX PLANNING STRUCTURES. PROTTECO TRUST COMPANY LTD ing. Tomáš Chrobák Executive Manager CZECH AND SLOVAK COMPANIES WITHIN INTERNATIONAL TAX PLANNING STRUCTURES PROTTECO TRUST COMPANY LTD ing. Tomáš Chrobák Executive Manager General information about the Czech Republic and Slovakia former

More information

WHY INVEST IN HOLLAND? because Holland offers a highly competitive fiscal climate

WHY INVEST IN HOLLAND? because Holland offers a highly competitive fiscal climate WHY INVEST IN HOLLAND? because Holland offers a highly competitive fiscal climate Introduction Netherlands Foreign Investment Agency (NFIA) The NFIA (Netherlands Foreign Investment Agency) is an operational

More information

Luxembourg-Hong Kong Double Tax Treaty: The Best of Both Worlds

Luxembourg-Hong Kong Double Tax Treaty: The Best of Both Worlds Tax Practice Luxembourg-Hong Kong Double Tax Treaty: The Best of Both Worlds Gerald Pasquier, Daniel Boone and David Maria examine the potential benefits for business connections between Asia and Europe

More information

Setting up your Business in Turkey Issues to consider

Setting up your Business in Turkey Issues to consider Turkey is located as a bridge between two continents and in close proximity to Europe, the Middle East and the Caucasus. The proximity to the Balkans and the rest of Europe as well as to the growing emerging

More information

An overview of using Hong Kong as a platform for trade and investment with China. Daniel Booth Director Vistra (Hong Kong)

An overview of using Hong Kong as a platform for trade and investment with China. Daniel Booth Director Vistra (Hong Kong) An overview of using Hong Kong as a platform for trade and investment with China Daniel Booth Director Vistra (Hong Kong) Breda May, 2012 The role of Hong Kong A recognized and respected jurisdiction for

More information

China issues new indirect equity transfer rules

China issues new indirect equity transfer rules from International Tax Services China issues new indirect equity transfer rules February 24, 2015 In brief China s State Administration of Taxation (SAT) released new rules regarding offshore indirect

More information

What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location for International Groups?

What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location for International Groups? UK CLIENT MEMORANDUM ENGLISH LAW UPDATES What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location May 13, 2014 AUTHOR Judith Harger Recent activity in the merger and M&A space

More information

Recent developments regarding Mexico s tax treaty network and relevant court precedents

Recent developments regarding Mexico s tax treaty network and relevant court precedents Recent developments regarding Mexico s tax treaty network and relevant court precedents Mexico has a relatively short background on the negotiation and application of treaties for the avoidance of double

More information

FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview

FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview The U.S. economic activities of foreign individuals and entities are classified as inbound transactions while the foreign economic

More information

Austrian Dividend Taxation Rules Are Partially Unacceptable, ECJ Says

Austrian Dividend Taxation Rules Are Partially Unacceptable, ECJ Says Volume 61, Number 12 March 21, 2011 Austrian Dividend Taxation Rules Are Partially Unacceptable, ECJ Says by Tom O Shea Reprinted from Tax Notes Int l, March 21, 2011, p. 927 Austrian Dividend Taxation

More information

DOING BUSINESS THROUGH MALTA - AN OVERVIEW

DOING BUSINESS THROUGH MALTA - AN OVERVIEW A. WHY MALTA 2 B. THE MALTESE COMPANY 2 C. MALTA TAX REFUNDS - LOWEST TAX IN THE EU 3 D. MALTESE TRADING STRUCTURE - 5% EFFECTIVE TAXATION Benefits and Uses of the Maltese Trading Company Basic Trading

More information

MALTA TRADING COMPANIES

MALTA TRADING COMPANIES MALTA TRADING COMPANIES Malta Trading Companies Maltese Registered Companies and Trading Operations in Malta Malta, an EU Member State since May 2004, has developed into a leading and reputable financial

More information

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies CORPORATE/LEGAL Incorporation time and costs Possible in 3 days app. EUR 2,500 Less than a week app. EUR 4,000 Up to 2 weeks

More information

Spanish Tax Facts. The Expatriate Financial Guide to Spain

Spanish Tax Facts. The Expatriate Financial Guide to Spain The Expatriate Financial Guide to Spain Spanish Tax Facts Introduction Tax Year Assessment Basis Taxation in Spain occurs at a national level and at a regional ( Autonomous Community ) or municipal level.

More information

MALTA TRADING COMPANIES IN MALTA

MALTA TRADING COMPANIES IN MALTA MALTA TRADING COMPANIES IN MALTA Trading companies in Malta 1. An effective jurisdiction for international trading operations 410.000 MALTA GMT +1 Located in the heart of the Mediterranean, Malta has always

More information

UAE TAX. Personal Tax

UAE TAX. Personal Tax UAE TAX This document aims to provide a brief outline of the laws and treaties in force in the UAE, an overview of the taxation regime in the UAE including a summary of the UAE double taxation treaties

More information

Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5%

Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5% Hong Kong Last reviewed: 18 March 2014 A. Companies 1. Resident companies Corporate tax rates 16.5% Tax base territorial Unilateral double taxation relief 2. Non- Corporate tax rates 16.5% on sale of shares

More information

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5 CORPORATE INCOME TAX IN BALTICS Corporate Income Tax Rates in Baltics Country Standard rate Decreased rate Transfer of loses to next periods Latvia 15% 11% microenterprises Unlimited Lithuania 15% Estonia

More information

CYPRUS: An Aviation Finance & Leasing Jurisdiction

CYPRUS: An Aviation Finance & Leasing Jurisdiction September, 2015 CYPRUS: An Aviation Finance & Leasing Jurisdiction Introduction Whilst there are many jurisdictions that are considered to be the jurisdictions of choice in the area of aviation finance

More information

The use of Cyprus structures in international tax planning

The use of Cyprus structures in international tax planning The use of Cyprus structures in international tax planning Tax and other advantages Tax planning ideas - structures 1 Terms of reference Purpose - basis of preparation - assumptions: This presentation

More information

COMPREHENSIVE BUSINESS SERVICES

COMPREHENSIVE BUSINESS SERVICES COMPREHENSIVE BUSINESS SERVICES CONTENTS About Cyprus... 02 Cyprus Tax Advantages... 04 About ANH Auditors - Consultants... 09 Audit... 10 Tax... 11 Business Consultancy... 12 Bookkeeping & Payroll...

More information

Implementation of the EU tax directives in Poland

Implementation of the EU tax directives in Poland Bartosz Bacia Implementation of the EU tax directives in Poland Since Poland joined the EU on May 1 2004, Polish tax law need to be adapted to the EU Council directives for the member states. The new legal

More information

THE TAXATION INSTITUTE OF HONG KONG CTA QUALIFYING EXAMINATION PILOT PAPER PAPER 5 ADVANCED TAXATION PRACTICE

THE TAXATION INSTITUTE OF HONG KONG CTA QUALIFYING EXAMINATION PILOT PAPER PAPER 5 ADVANCED TAXATION PRACTICE THE TAXATION INSTITUTE OF HONG KONG CTA QUALIFYING EXAMINATION PILOT PAPER PAPER 5 ADVANCED TAXATION PRACTICE Advance Tax- pilot_1007_q&a_jy R28/3/2013 1 QUESTIONS Section A Case Answer Question 1 in this

More information

Annual Tax Return Guide

Annual Tax Return Guide Annual Tax Return Guide 2015 Retail Responsible Entity Limited ABN 80 145 213 663 1.0 Background The purpose of this document is to provide a guide as to the potential NZ and Australian income taxation

More information

China s Controlled Foreign Corporation (CFC) Rules

China s Controlled Foreign Corporation (CFC) Rules China s Controlled Foreign Corporation (CFC) Rules Liao Tizhong: Deputy Director General of International Taxation of the State Administration of Taxation of the P. R. China In 2008, China launched a major

More information

Updated Regulations regarding Withholding Tax in China

Updated Regulations regarding Withholding Tax in China Updated Regulations regarding Withholding Tax in China Fiona Fan Director, Accounting Services NCO China Oct 13, 2010 Agenda Key concepts and regulations about withholding tax in China Relationship between

More information

TAX PRESENTATION. By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP

TAX PRESENTATION. By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP TAX PRESENTATION By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP 1 Table of Contents 1. Immigration Tax and EB-5 5 Planning (a) (b) (c) (d) (e) (f) Pre-departure planning

More information

Investing into India through Mauritius

Investing into India through Mauritius BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS CYPRUS DUBAI HONG KONG LONDON MAURITIUS MOSCOW SÃO PAULO SINGAPORE conyersdill.com July 2010 Investing into India through Mauritius Mauritius Funds Mauritius

More information

Cross Border Tax Planning Checklist

Cross Border Tax Planning Checklist Cross Border Tax Planning Checklist & c o m p a n y l l p Accountants & International Tax Consultants 101 2 nd Street, Suite 1200 San Francisco, California 94105 www.rowbotham.com Page 1 Income Tax Residents

More information

Uganda Fiscal Guide 2012/13 kpmg.com

Uganda Fiscal Guide 2012/13 kpmg.com Tax Uganda Fiscal Guide 2012/13 kpmg.com Introduction: Uganda Fiscal Guide 2012/13 Income tax Basis of taxation Income tax is levied on both companies and individuals under the Income Tax Act, (Cap 340)

More information

UPDATE ON NON-RESIDENT INVESTMENT IN CANADIAN REAL ESTATE

UPDATE ON NON-RESIDENT INVESTMENT IN CANADIAN REAL ESTATE Page 1 of 9 UPDATE ON NON-RESIDENT INVESTMENT IN CANADIAN REAL ESTATE Jack Bernstein Aird & Berlis LLP Toronto, Canada To be submitted for publication in Tax Notes International, 2015 The stable Canadian

More information

Taxand Asia Senior School CONTROLLED FOREIGN COMPANIES

Taxand Asia Senior School CONTROLLED FOREIGN COMPANIES Taxand Asia Senior School CONTROLLED FOREIGN COMPANIES OUTLINE Controlled Foreign Company ( CFC ) - the concept CFC The international scenario A comparative with other jurisdictions CFC and the Indian

More information

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk Chapter Avbreht, Zajc & Partners Ltd. Ursula Smuk 1 General: Treaties 1.1 How many income tax treaties are currently in force in? 44 income tax treaties are currently in force in. 1.2 Do they generally

More information

TAXATION OF CROSS-BORDER DIVI-

TAXATION OF CROSS-BORDER DIVI- DG Taxation and Customs Union TAXATION OF CROSS-BORDER DIVI- DEND PAYMENTS WITHIN THE EU IMPACTS OF SEVERAL POSSIBLE SOLUTIONS TO ALLEVIATE DOUBLE TAXATION 22 JUNE 2012 COLOPHON Disclaimer This report

More information

German Tax Facts. The Expatriate Financial Guide to Germany

German Tax Facts. The Expatriate Financial Guide to Germany The Expatriate Financial Guide to Germany German Tax Facts Introduction Tax Year Assessment Basis Income Tax Taxation in Germany occurs at a national and municipal level. The Ministry of Finance controls

More information

Setting up your Business in The Netherlands Issues to consider

Setting up your Business in The Netherlands Issues to consider The Netherlands, with a historically strong economic financial climate, is traditionally an important gateway to Europe. Situated in the western part of the European continent with its world leading Rotterdam

More information

Oppor o t r unit i ie i s e s W it i hin i T h T e e M alt l e t s e e s e Fin i ancia i l l S ec e to t r o Banking

Oppor o t r unit i ie i s e s W it i hin i T h T e e M alt l e t s e e s e Fin i ancia i l l S ec e to t r o Banking Opportunities Within The Maltese Financial Sector Banking Growth of the Industry Malta s international banking centre has been gaining considerable ground in establishing itself as a finance hub in the

More information

Taxation Dutch resident investors

Taxation Dutch resident investors Taxation Dutch resident investors The effective tax rate on ishares investments depends on the personal circumstances of each shareholder. The content in the following paragraphs is for information purposes

More information

THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY

THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY Ideal Characteristics for the Location of an International Holding Company Laurence Binge +44 (0)1372 471117 laurence.binge@woolford.co.uk www.woolford.co.uk

More information

Austria A perfect gateway between East and West

Austria A perfect gateway between East and West Austria A perfect gateway between East and West Erich Certified Baier, Tax MBA, Advisor LL.M. 1 / 58 1 /77 Austria A A perfect gateway between East East and and West Wie auch immer das ausschauen 25 th

More information

EMPLOYMENT INCOME INCOME TAX IMPLICATIONS

EMPLOYMENT INCOME INCOME TAX IMPLICATIONS EMPLOYMENT INCOME INCOME TAX IMPLICATIONS June 2009 Index 1 Background... 1 2 Income tax implications for individuals... 1 2.1 Resident and domiciled individuals... 2 2.2 Resident or domiciled individuals...

More information

Portuguese Taxation of Investments in Hong Kong. Oporto, March 31, 2010

Portuguese Taxation of Investments in Hong Kong. Oporto, March 31, 2010 Portuguese Taxation of Investments in Hong Kong Oporto, March 31, 2010 Summary Hong Kong legal environment: main topics Overview on tax aspects: Hong Kong taxation on profits Portuguese taxation on dividends

More information

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK

TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK TRINIDAD AND TOBAGO Introduction TAX PRACTICE GROUP Multi-Jurisdictional Survey TAX DESK BOOK CONTACT INFORMATION Myrna Robinson-Walters M. Hamel-Smith &Co Eleven Albion, Dere and Albion Streets, Port-of-Spain,Trinidad

More information

International Tax Alert

International Tax Alert Global Insights A Review of Key Regulatory Issues Impacting International Tax Practices European Union: German dividend withholding tax violates the principle of free movement of capital (ECJ, October

More information

Your guide to taxation in India

Your guide to taxation in India Sharing our experience Your guide to taxation in India www.fpinternational.com The tax treatment of our products if you return to India Whilst tax planning might be an important part of your overall financial

More information

International aspects of taxation in the Netherlands

International aspects of taxation in the Netherlands International aspects of taxation in the Netherlands Individuals resident in the Netherlands are subject to income tax on their worldwide income. Companies established in the Netherlands are subject to

More information

Hong Kong. The 2013/14 budget. Salaries tax. Profits tax. One-off relief measures

Hong Kong. The 2013/14 budget. Salaries tax. Profits tax. One-off relief measures Hong Kong Extending the concessionary profits tax rate (i.e. 50% of the normal profits tax rate) currently applicable to offshore reinsurance business to the offshore insurance business of captive insurance

More information

This article provides an overview of the key proposals in the DTC and their impact on both domestic and international businesses in India.

This article provides an overview of the key proposals in the DTC and their impact on both domestic and international businesses in India. The Government of India had released the draft Direct Tax Code ( DTC ) along with a Discussion Paper in August 2009 for public comments. Various stakeholders have provided their feedback and the Government

More information

U.S. Taxation of Foreign Investors

U.S. Taxation of Foreign Investors PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAX

More information

O MELVENY. Indonesian Equity Investments Selecting a Tax Efficient Holding Jurisdiction

O MELVENY. Indonesian Equity Investments Selecting a Tax Efficient Holding Jurisdiction O MELVENY Indonesian Equity Investments Selecting a Tax Efficient Holding Jurisdiction A comparison of Hong Kong and Singapore in light of the new Hong Kong-Indonesia tax treaty Joel Hogarth +65-6593-1866

More information

Hong Kong s Double Tax Treaty Network

Hong Kong s Double Tax Treaty Network TAX FLASH July 2010 TAX FLASH July 2010 Hong Kong s Double Tax Treaty Network To remain as an international financial and commercial centre, it has become important for Hong Kong to promote its transparency

More information

Review of Current Practices for Taxation of Financial Instruments, Profits and Remuneration of the Financial Sector

Review of Current Practices for Taxation of Financial Instruments, Profits and Remuneration of the Financial Sector TAXATION PAPERS WORKING PAPER N.31-2012 PwC Review of Current Practices for Taxation of Financial Instruments, Profits and Remuneration of the Financial Sector Taxation and customs union Taxation Papers

More information

Real estate acquisition structures in Europe: the main tax issues

Real estate acquisition structures in Europe: the main tax issues Real estate acquisition structures in Europe: the main tax issues The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax Conference - Thursday 9 February

More information

Addendum. This addendum set out changes to be made in the Statement of Additional Information (SAI) of Tata Mutual Fund.

Addendum. This addendum set out changes to be made in the Statement of Additional Information (SAI) of Tata Mutual Fund. Addendum This addendum set out changes to be made in the Statement of Additional Information (SAI) of Tata Mutual Fund. Date of Enactment of Finance Bill 2015: 14th May 2015 Section VI. TAX & LEGAL & GENERAL

More information

Corporate Taxation COPYRIGHT WDM INTERNATIONAL

Corporate Taxation COPYRIGHT WDM INTERNATIONAL Corporate Taxation COPYRIGHT 2013 - WDM INTERNATIONAL Contents Malta s corporate tax system Registration procedure and Formation formalities basis of taxation full imputation system tax accounting tax

More information

THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION

THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION THE MADEIRA INTERNATIONAL BUSINESS CENTRE MADEIRA COMPANY INFORMATION A GENERAL OVERVIEW The Madeira International Business Centre (MIBC) is an established and important international business hub, wholly

More information

TAX PLANNING INTERNATIONAL

TAX PLANNING INTERNATIONAL TAX PLANNING INTERNATIONAL EUROPEAN TAX SERVICE International Information for International Business >>>>>>>>>>>>>>>>>>>>>>>>>>>>> VOLUME 17, NUMBER 3 >>> MARCH 2015 www.bna.com EU Financial Transaction

More information

Application of Treaties to Nonresidents: Taxation of Capital Gains

Application of Treaties to Nonresidents: Taxation of Capital Gains Application of Treaties to Nonresidents: Taxation of Capital Gains Diane Ring Professor of Tax Law Boston College Law School UN-ITC Workshop on Administration of Tax Treaties and Addressing Base-Eroding

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser Value through Wealth Planning - Key trends in Prof. Pierre-Marie Glauser Introduction (1) Wealth Management & Taxes Funds are Not declared Declared No taxes due Tax planning not necessary Relevant tax

More information

Malta Country Profile

Malta Country Profile Malta Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Australia Austria

More information

REVIEW OF MAURITIUS-NIGERIA DOUBLE TAXATION TREATY

REVIEW OF MAURITIUS-NIGERIA DOUBLE TAXATION TREATY REVIEW OF MAURITIUS-NIGERIA DOUBLE TAXATION TREATY Background information In August 2012, representatives of the governments of Mauritius and Nigeria signed an income tax treaty. Also signed was a Protocol

More information

Setting up your Business in SINGAPORE Issues to consider

Setting up your Business in SINGAPORE Issues to consider SINGAPORE is commerce, industry, heritage, culture and entertainment all rolled into a little island of slightly over 700 square kilometres with a population of 5.4 million. Here at the crossroads of Asia,

More information

CHAPTER 21 INTERNATIONAL TAX ENVIRONMENT AND TRANSFER PRICING SUGGESTED ANSWERS AND SOLUTIONS TO END-OF-CHAPTER QUESTIONS AND PROBLEMS

CHAPTER 21 INTERNATIONAL TAX ENVIRONMENT AND TRANSFER PRICING SUGGESTED ANSWERS AND SOLUTIONS TO END-OF-CHAPTER QUESTIONS AND PROBLEMS CHAPTER 21 INTERNATIONAL TAX ENVIRONMENT AND TRANSFER PRICING SUGGESTED ANSWERS AND SOLUTIONS TO END-OF-CHAPTER QUESTIONS AND PROBLEMS QUESTIONS 1. Discuss the twin objectives of taxation. Be sure to define

More information

MALTA: A JURISDICTION OF CHOICE

MALTA: A JURISDICTION OF CHOICE MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive

More information

Software Tax Characterization Helpdesk Quarterly April 2012

Software Tax Characterization Helpdesk Quarterly April 2012 Software Tax Characterization Helpdesk Quarterly April 2012 Characterizing foreign software revenues is a complex challenge for large and small software firms alike. Variations in the rules around the

More information

1. Israeli Tax Treaties General Overview

1. Israeli Tax Treaties General Overview 1. Israeli Tax Treaties General Overview This year marks Israel's 60 th anniversary. The country is known for having a relatively high volume of international economic activity, both incoming and outgoing

More information