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Recent News

Cyprus Imposes 19% VAT on Building Land

Published: 19/01/2018 | news

From January 2, 2018 in Cyprus, the new VAT Law has entered into force, providing for changes in the main VAT Law No.95(I)/2000. The document introduces VAT at a standard rate for the sale of building land, as well as leasing/rental of business premises on the conditions specified in the law. It also introduces the reverse charge mechanism for VAT-subject supplies of land and property under a loan restructuring/force-sale arrangement, which will mostly influence financial institutions. Imposition of VAT at the standard rate of 19% on building land The standard VAT rate of 19% will be applied in the following cases: transfer of ownership; transfer of indivisible land portion; transfer of ownership via contract or sale agreement or agreement which specifies that the ownership will be transferred in the future or leasing agreement with buyout option. The above shall apply to non-developed building land which is meant for the construction of one or more structures in the course of carrying out a business activity. More clarifications are still needed for the application of the law, such as the circumstances whereby a transfer is not considered to be a part of a person’s...

Ministry of Finance Reforms Institution of Financial Liability for Tax Violations

Published: 30/11/2017 | news

Recently the Ministry of Finances of Ukraine, together with the experts from the interactive tax platform TaxLink, has developed a bill “On Amendments to the Tax Code of Ukraine regarding the improvement of the prosecution system for violation of tax laws”. The essence of the document is to reform the liability for tax violations provided by the current legislation. First of all, the bill introduces more effective mechanisms for the settlement of tax disputes in cases when the violation of tax law happened not due to the fault of the payer. In addition, it is proposed to introduce the principle of fault liability of taxpayers which is inherent in all branches of Ukrainian legislation, in contrast to the current liability of the payer without fault. Therefore, the last one will be considered guilty if found guilty that he was able to comply with the relevant rules and regulations, but did not take the necessary measures for this. In this regard, when considering the verification materials by the supervisory authority, the documents of the taxpayer may be subject to the examination that show his due diligence. Another significant innovation is the introduction of the system of...

Undistributed profit in Latvia is exempt from CIT

Published: 01/09/2017 | news

On the 4th and 11th of July, 2017 the Cabinet of Ministers of Latvia approved a number of draft laws providing for the significant changes in the tax legislation of the country which will enter into force on January 1, 2018. The most significant of them will be the application of the CIT 0% rate for the reinvested profits. In other words, the enterprise will be subject to the corporate income tax only if it pays dividends or other payments for the purpose of actual distribution of the profits (conditionally distributed profit). Therefore since 2018, the company's profits are exempted from CIT, but it has to pay 20% of the income tax from the amount of dividends. At the same time, the shareholders will not have to pay personal income tax (PIT). Although, according to the bill, the CIT rate is 20%, and the tax base should be divided by a factor of 0.8, the effective tax rate actually equals 25%. It is notably that CIT will be applied not only to the dividends in the traditional sense, but also to the "deemed dividends", which are considered a new concept in Latvian tax legislation, and comparable with the dividends to the costs. Here it is important to note that the last ones...

Netherlands announces tax plan

Published: 22/09/2016 | news

The Dutch government has announced measures to simplify aspects of the tax regime and the tax administration. The majority of people will get tax cuts, certain tax procedures will be simplified, and the Dutch tax will be changed to the mode of dividend under the new tax plan, announced by the Ministry of Finance of 20 September, small and medium-sized businesses. Proposed dividend tax changes aimed at leveling the tax treatment of dividends to the holding of cooperatives, which are frequently used in international structures of the holding company, along with private companies (BVS) and public companies (PNV). Under existing rules, holding cooperatives, as a rule, are not subject to tax on dividends in the Netherlands, in contrast to the terminal and NVs. The government intends to eliminate this difference, but at the same time to release the distribution of dividend tax in cases where shareholders holding cooperative, the NV or BV, residing in a jurisdiction with a tax treaty with the Netherlands, subject to a minimum of five per cent threshold of holding. These changes are expected to be introduced from 1 January 2018. With regard to income tax, the ministry said that "the...

Changes in order payment of dividends by joint stock companies

Published: 03/06/2016 | news

May 27, 2016 came into force The order payment of dividends by joint stock company, which is approved by the National Commission on securities and stock market from 12.04.2016 number 391. In particular, on the relevant general meeting of shareholders is defined by a specific method of payment of dividends concerning the entire issue of shares - through the depository system of Ukraine or directly to shareholders. Implementation of dividend payments by joint stock company is going through the payment of the entire amount in full or in part, certainly if it is provided by the general meeting of shareholders or the supervisory board of the company. At the same time, in the case of decision-making by the joint stock company to pay dividends to shares, the payment could made proportionally and simultaneously to all persons who are entitled to receive dividends. Regarding the payment of dividends directly to shareholders. Payment of dividends to shareholders who are entitled, namely the transfer of the amounts of funds to all shareholders shall be effected by the transfer of funds to the shareholders during the relevant time and date that does not exceed six...

Puerto Rico’s VAT plans was declined by lawmakers

Published: 31/05/2016 | news

Puerto Rico will no longer accept the value added tax, after lawmakers in the Senate voted in favor of the overthrow of the attempts of the governor of Puerto Rico, Alejandro Garcia Padilla, to veto the previously adopted law on the abolition. Puerto Rico was to introduce value added tax at the point of sales and use tax from 1 of June The Senate of Puerto Rico, May 5, 2016, unanimously supported the earlier legislation with the support of the lower house of Parliament on 2 May to prevent value-added tax from being introduced.. The governor then vetoed the legislation. However, the legislation is only necessary to collect two-thirds support to override this veto. May 26, 2016, the Senate voted to abandon plans for VAT 21 votes to 1. Author: Sergey Panovmanaging partner Finance Business...

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

Published: 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 Rate 2016 Classical offshores

Published: 19/03/2016 | news

Gibraltar - Corporate tax rate is 10%. Cayman Islands - No income tax. Dominica - Rate reduce from 28% to 25% on 1 January 2016/ Branch remittance tax of 15% also levied. Labuan - Tax rate is 3% or 20.000 MYR per year. Gibraltar - Corporate tax rate is 10%. Cayman Islands - No income tax. Dominica - Rate reduce from 28% to 25% on 1 January 2016/ Branch remittance tax of 15% also levied. Labuan - Tax rate is 3% or 20.000 MYR per year. Isle of Man - Standard income tax rate for companies is 0%. Income received in respect of licensed banking activity and retail profits for companies undertaking Isle of Man retail business where annual taxable profit from this business exceeds GBP 500,000 taxed at 10% rate. Profits from Isle of Man land and property taxed at rate 20%. Jersey - Standard rate of corporate income tax applying to Jersey resident companies or non-Jersey resident companies that have permanent establishment in Jersey is 0%. 10% rate applies to certain companies that meet definition of "financial services company" and 20% rate applies to certain companies that meet definition of "utility company." St. Kitts & Nevis - Rate is 33%. Remittances...

Corporate Tax Rate 2016

Published: 17/03/2016 | news

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: 01/03/2016 | news

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...