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Undistributed profit in Latvia is exempt from CIT

Published: 01/09/2017 | news

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#CIT #CIT #Dividends

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...

New Zealand seeks tax transparency from MNEs

Published: 24/11/2016 | news

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#New Zealand

The Commissioner of New Zealand tax management, Naomi Ferguson turned to local and multinational corporations belonging to a foreign owner to be more transparent in their international tax matters. Ferguson made the call Chartered Accountants of Australia during the launch of the 2016 edition of the Document of Compliance the center of transnational corporations and in Auckland on November 18 held a tax conference of New Zealand. The document of compliance describes in detail as the tax authority continues to increase amount of a research of large corporations, increasing number of the companies which will receive closer attention. The New Zealand large companies will be obliged to represent the Main Packet of Compliance which will include annual information on their structure of group, the financial reporting and tax coordination while the companies belonging to the foreign owner are obliged to finish the intended International Questionnaire. According to the internal income, nearly 600 New Zealand and foreign groups were under observation since 2012. From next year this number increased almost to 900 groups, including all the multinational companies belonging to foreign...

Hungary plans the lowest corporate tax of the EU

Published: 21/11/2016 | news

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#EU #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 ...

Fund of Luxembourg is considering reducing taxes for Britain

Published: 11/10/2016 | news

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#Funds #Luxembourg

Henderson Diversified investment trust said that it is considering the transfer of its Luxembourg subsidiary of the United Kingdom, referring to the growing fiscal risks in the Grand Duchy. In a statement released to the London Stock Exchange on October 7, Henderson said that some recent developments in tax law and practice of Luxembourg increased the legal risks of operating within the jurisdiction, including the transfer pricing. "The Board of Directors and its advisors continue to review these developments and the recently concluded that the existing structure of the company may include increased complexity and risk," said Henderson. "Accordingly, the Council examining the possibility of simplifying the tax structure by election and joining the UK investment trust tax regime, including changing its place of registration in the United Kingdom," added the firm. Such a move is likely to lead to the liquidation of its subsidiary in Luxembourg and the formation of a new company in the UK, which is expected to reduce its annual operating costs. The company said its investment management arrangements will not be affected by this reorganization. However, he confirmed that it...

New Zealand tax system progresses

Published: 07/09/2016 | news

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#New Zealand

The top ten income in New Zealand is projected to pay 37.2% income tax in 2016/17, compared with 35.5% in the 2007/08 year. The New Zealand government has published data showing that the tax system is more progressive. "These latest data confirm that the income tax system and support of New Zealand much income redistribution needy households, said Acting Finance Minister Steven Joyce. "Many families with low incomes pay a larger share of income tax than in 2008, and households with low incomes pay less - 30% of households with the lowest incomes are projected to pay only 5.4% of income tax, compared with 6.3% in 2007/08 p ". "The Government has increased support to low-income households to help New Zealanders go through difficult times. So at any given time, a large number of households effectively do not pay income tax," said Joyce. According to the Treasury in 2016/17, 42% of households will pay less tax than they receive from social security benefits it work for family tax credits and if we compare, the 2007/08 figure was - 39%. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

DTA entered into force between Russia and Hong Kong

Published: 08/08/2016 | news

Tags:

#Double taxation #Exchange of tax information #Hong Kong #Russia

Comprehensive agreement for the avoidance of double taxation (CDTA) was signed in January of this year between Hong Kong and Russia, which came into force on 29 July 2016. According to the sources, this agreement shall remain in force for Hong Kong each year since its signing to double taxation, which took place on or after April 1, 2017. The CDTA is informed about what is required to support efforts to expand the tax obligations undertaken by the two countries in the framework of the «Belt and Road», which is a project of the Chinese government for the economic development aiming at the integration of trade and investment between the approximately 60 countries in Eurasia. In the absence of the CDTA program, of Hong Kong companies income, which conduct their entrepreneurial activities with the help of permanent missions in Russia and taxed in both places if their earnings was received in Hong Kong. On this basis, in the new agreement, double taxation is eliminated, and now any Russian tax paid by the companies on their earnings, will be allowed to tax payable in Hong Kong. Besides, in accordance with this agreement, the rate in Russia on income tax on royalties,...

Luxembourg reviewing verdict on LuxLeaks

Published: 04/08/2016 | news

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#Luxembourg

Luxembourg public prosecutor lodged an appeal against the verdict on the recent so-called scandal "LuxLeaks", arguing that the sentences imposed by the court was too lenient. Earlier this year, Antoine Deltour and Raphael Halet, both former employees of PricewaterhouseCoopers (PwC) consulting firm, received suspended sentences by the court 12 and 9 months, respectively, for their role in the disclosure of thousands of documents detailing the private tax ruling between multinational companies and the tax authority of Luxembourg. They also had to pay a fine of 1,500 EUR (1,680 USD) and 1,000 EUR, respectively. A third defendant, a French journalist Edouard Perrin, who made the initial discovery of LuxLeak and the first to publish the story on French television, was acquitted of all charges. Let us recall that in this scandal for the exemplary data were involved 340 major transnational and national companies from around the world. It is believed that the defendants, with the support of the local authorities thought out and implemented an elaborate scheme of tax evasion, in some cases, reducing the payout to just 1%. The defendants face various charges during the...

EU signed tax agreement with IOTA

Published: 01/08/2016 | news

Tags:

#EU #Exchange of tax information

The Intra-European Organization of Tax Administrations (IOTA ) has signed tax agreement with European Commission to develop the solution of more effective way to common targets which this two brunches are working on and also one kind of them activity to prevent double tax avoidance. According to announce of IOTA 26 of July the main brunches of co-working in agreement frames include battle against swindle, information exchange, alternate support, support of tax departments to increase the level of maintenance by taxpayers. The agreement was signed between IOTA and the Taxation and Customs Union Directorate General (DG TAXUD) of the European Commission 7 of July. Edery said: «Commission has get a support IOTA from the day it start exist and attentively watching it progress. We have common target to support European states in development and modernization of tax administration. Based in Budapest, IOTA is a non-profit intergovernmental organization, created to promote using the best practice in tax administration direction and more effective co-working with 46 tax authorities’ members. Author: Olena Kutova senior lawyer of the Finance...

Italian-Swiss TIEA goes into force

Published: 27/07/2016 | news

Tags:

#Exchange of tax information #Italy #Switzerland

The Italiam Ministry of economy and finance claimed that protocol about tax information of double tax agreement between Italy and Switzerland wich was signed 23 of February, 2016 goes into force 13 of July, 2016. The agreement protocol comprises all kind of taxes, point out that country can't deny to represent asking information only because this information has in keeping on bank or any other financial constitution. Much less the country need to empty of all own inner legal proceedings before than protocol can ask information from other. Also need to indicate person or persons who are the object of asking request, period of time need to ask the information, descrabing of information need to and the reason of request if its known, the name and adress of suppose owner of information. This specifications was added for avoiding any want of judgment, general compromative information, and he also added that the second list of specifications don't using for placing obstacles on the way of effective agreements between these countries. This protocol also approves that this contributions will use retrospectively to the data that existed prior to or after the date of...

New Zealand propose to improve invest tax

Published: 11/07/2016 | news

Tags:

#Investments #New Zealand

The government of New Zealand release 7 July 2016 discussion document contain proposals aiming for improving administrative invest tax. These proposals can make easy a year process for taxpayers and increase in the system at the same time, Revenue Minister Michael Woodhouse said. "Payers of interest, dividends, and taxable Maori authority distributions currently provide tax certificates to the recipients of the income. Need to gather all of this certificates from it different income sources to meet their end of year tax obligations." Woodhouse said. It would be better for income to collect that entire information collect that information direct from the payers and use it to pre-populate the recipients' tax records." To get this target the discussion document proposes that: All investment income payers will provide this information to the Internal Revenue often. The deadline for feedback on the proposals on 19 August 2016. Author: Sergey Panovmanaging partner Finance Business...

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