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Author: Сергей Панов

Hungary plans the lowest corporate tax of the EU

Published: Sergey Panov | 21/11/2016 | news
Hungary

Mihaly Varga, Hungary's Minister of National Economy, announced about decision of government to reduce the corporate tax rate lower than 10 percent next year. On November 18, behind the scenes of the Regional Digital Conference in Budapest, he made the announcement during which he unveiled the plan of the government to impose a single rate for nine percent of the corporate tax. Now, the headline shows, that the rate of Hungary of the corporate tax constitutes 19 percent, and there is lower level of the income tax of 10 percent on the first 500 million Hungarian forints (1.7 million US dollars) of the income. Dramatic movement would give Hungary one of the lowest corporate tax rates in the world and one of the lowest in the European Union "onshore" jurisdictions. Varga said that this measure will save companies about 145 billion HUF (500 million US dollars) a year tax. The Government expects to compensate the shortfall through controlled growth to increase tax revenues. The government plans to introduce a new tax rate of 1 January 2017. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

Amendments to the intellectual property regime in the Republic of Cyprus

Published: Sergey Panov | 26/10/2016 | blog
Cyprus - Flag

October 14, 2016 in order to bring legislation into line with the BEPS requirements (plan to counter the erosion of the tax base and output gains from taxation), the Government of the Republic of Cyprus passed a law that introduces a number of amendments to existing intellectual property regime (hereinafter - the EC). These amendments to the IP regime came into force on 07.01.2016 year. It should be noted that until now existed in Cyprus IP regime has not been approved by the majority of EU member states, as well as been widely criticized. So, focus on the main points of the IP regime change which, in our view, require attention. First, once it is worth to note that the tax rate for the use of intellectual property (hereinafter - IS) unchanged at 2.5%. To determine the qualifying EC introduced a modified factor relation criterion (modified nexus approach). According to this criterion, the definition of qualifying IP narrowed. This factor suggests a link between the cost of the development of IP, most IP and income produced by the IP data objects. In this approach, the taxpayer must itself carry out research and development work (hereinafter - R & D). In addition, a special...

Future changes in the Convention between Ukraine and Cyprus on avoidance of double taxation

Published: Sergey Panov | 29/09/2016 | blog
Park in Cyprus

The Ukrainian parliament is currently being finalized for submission to the discussion of the draft law on ratification of the Protocol amending the Convention between the Government of Ukraine and the Government of the Republic of Cyprus for the avoidance of double taxation and prevention of tax evasion on income tax. This Protocol provides for changes in the taxation of dividends, interest on loans, as well as the alienation of the property income. With regard to dividends, the top rate will be reduced from 15 to 10%. But lower tax rate - 5% survive only if ownership of at least 20% of the capital of a legal entity. But how exactly a person - remains a mystery, as in the original text of the Protocol stated "Partnership About", ie the "Partnership", while the bill "Partnership About" translated as "Society". As such, this provision leaves room for corruption because it allows you to abuse the tax authority in determining the rate that must be applied by the payer. The rate of taxation of interest on loans increased from 2% to 5%. Changes are also proposed concerning the taxation of income from the alienation of shares and corporate rights. Unfortunately, due to the...

Parliament of Holland approves gambling tax

Published: Sergey Panov | 18/07/2016 | news
Gambling tax. Holland

The lower house of Dutch parliament approved rule, which can regulate and provide online gambling taxation. Remote Gambling Bill has plan to open Dutch gambling market for foreign outer gambling companies which provide taxation about 29 percent of gamble gross revenue, the same way of taxation have had already gamble land-based operators. According to previous version of draft law, tax for online gambling fixed about 20 percent. The acting coalition included remark to legislation in the beginning of this year for agreement this tax. Nevertheless, the final version of this law approved by the law house 7 July contains measure of decreasing about 25 percent at the end of three years period. In this proposing for the first time was planned to go into force this rule in 2015, but now they were waiting for voting in the Senate. In case of approving by upper house, expect that the process of application submission a new license for gambling in the first half of the next year, and that this new regime will fully up in the middle of 2017 year. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

Hong Kong, free trade negotiations with Georgia and the Maldives

Published: Sergey Panov | 11/05/2016 | news
Hong Kong, Georgia and Maldives

The government announced that in Hong Kong in the near future there will be an agreement on free trade after negotiations with Georgia and the Maldives. The government also prepared a document for consultation to interested parties could submit proposals for the areas to be covered in the two agreements. "Georgia and the Maldives is the emerging markets with the potential for further growth. The conclusion of free trade agreements with these two countries is of strategic importance for Hong Kong. These agreements after their signing will enhance Hong Kong's trade network in their respective regions, including Eurasia" the spokesman said. "In order to minimize the risk of marginalization, it is important for Hong Kong to participate in the negotiation of free trade agreements. The negotiations with the mainland of China which is our largest trading partner, accounting for about 50 percent of the total trade, have a special importance for maintaining Hong Kong's position as a major trade and logistics center, "he added. The provisions of the two new free-trade agreements will include the elimination or reduction of tariffs; the liberalization of non-tariff...

The agreement on the avoidance of double taxation changes, Ukraine – Cyprus

Published: Sergey Panov | 06/04/2016 | news

The Ukrainian government has announced a change to the existing agreements on avoidance of double taxation signed with Cyprus. The revised text will close a loophole that led to the fact that the income from immovable property situated in Ukraine avoid taxation in Ukraine. Income derived by a Cyprus resident from the sale of shares or other corporate rights will be subject to taxation in Ukraine if more than 50 percent of this revenue is directly or indirectly related to income immovable property situated on the territory of Ukraine. The minimum rate on dividends is increased from two percent to five percent. This low rate is used when the recipient owns 20 or more percent of the company distributing dividends and investment at least EUR 100,000 to obtain holding. The tax rate of ten percent is used otherwise. The revised section on dividends will come into effect not earlier than 1 January 2019. Other changes proposed to bring in agreement with the latest international tax standards developed by the Organization for Economic Cooperation and Development. The amendment has been sent to the Ukrainian legislators for approval. Author: Sergey...

Corporate tax 2016

Published: Sergey Panov | 21/03/2016 | news

Austria - Rate is 25%. Minimum corporate income tax of EUR 1,750 for limited liability company and EUR 3,500 for joint stock company. Belgium - Corporate tax rate is 33%. Surcharge of 3% on income tax due makes effective tax rate 33,99%. Reduced rates may be available for companies whose taxable income does not exceed EUR 322,500. Germany - Tax rate is 15%. Solidarity surcharge of 5,5% also levied on corporate income tax. Municipal trade tax imposed at rates between 14% and 17%, with rates determined by municipalities. Combined rate approximately 30% to 33%. Hungary - 10% rate applies to tax base up to HUF million, 19% rate applies to tax base exceeding this amount. Denmark - Rate reduced from 23,5% to 22% on 1 January 2016. Macao - Rate is 0% on assessable profit up to MOP 600,000; 12% rate applies to assessable profit over that amount. Monaco - Rate is 33,33% Netherlands - Rate is 20% on taxable profits up to EUR 200,000 and 25% on taxable profits exceeding that amount. Slovakia - Corporate tax rate is 22%. Luxembourg - 21% rate applies to companies whose taxable income exceeds EUR 15,000; otherwise, rate is 20%. Surtax of 7% to unemployment...

Corporate Tax Rate 2016

Published: Sergey Panov | 17/03/2016 | news
Corporate tax in 2016

UK - The Corporation Tax main rate for 1 April 2016 is set at 20%. This rate will fall to 19% for the year beginning 1 April 2017, and to 18% for the year beginning 1 April 2020. Hong Kong - Profits tax levied at rate of 16,5% for companies carrying on business in Hong Kong (and 15% for unincorporated businesses) on relevant income earned in or derived from Hong Kong. Ireland - Standard corporation tax rate on trading income is 12,5% and 25% on non-trading income. Cyprus - Corporate tax rate is 12,5%. Certain types of income subject to Special Contribution for Defense at rates of 17%(dividends), 30%(interest) and 3%(rents). Latvia – Rate is 15%. Belize - All non-CARICOM residents, who have any taxable receipts originating from Belize, or in respect of any service provided in Belize, are required to pay business taxes as follows: Dividends - 15%, Insurance Premiums - 25%, Interest on Loans - 15%, Management fees - 25%, Rental of plant and equipment - 25%, Technical Services - 25%. British Virgin Islands - No income tax. United Arab Emirates - Income tax decrees currently enforced on oil and gas companies and branches of foreign banks. Oil and gas...

Double tax treaty between Cyprus and Switzerland

Published: Sergey Panov | 01/03/2016 | news
Cyprus and Switzerland

The first Cyprus-Switzerland double tax treaty (DTT), signed in 2014, entered into force in October 2015 with its provisions taking effect as from January 1, 2016. Under the treaty there is no withholding tax (WHT) on interest and royalties. There is also no WHT on dividends in those cases where the beneficial owner of the dividends is: a company (other than a partnership), the capital of which is wholly or partly divided into shares, holding directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of at least one year (the time period criterion may be satisfied post the date of the dividend payment), or a pension fund or similar institution recognized as such for tax purposes, or the government, a political subdivision, local authority, or the central bank of one of the two Contracting States. Per the treaty, a 15% WHT on dividends applies in all other cases. Irrespective of this, per the provisions of Cyprus’ domestic tax legislation, Cyprus does not apply WHT on dividend payments out of Cyprus at all times. Author: Sergey Panovmanaging partner Finance Business...