CA. Divakar Vijayasarathy
|
|
- Norman Murphy
- 5 years ago
- Views:
Transcription
1 CA. Divakar Vijayasarathy Introduction Tax and Regulatory Regime in India Global Estate Tax Regime Possible Estate Planning Structures Practical Perspective to Estate Tax Planning 1
2 Death leads to movement of property from the deceased to their successors Succession could be testamentary or intestate Intestate succession could lead to appointment of an administrator Taxes shall be applicable on: Succession Appointment of administrator Transfer of property from administrator to ultimate successor 2
3 For tax parlance, death means: - Death of a living person - Prolonged absence of a living person. - Presumption based on period of absence & - Judicial review Succession law in most countries have multiple implications There could be a State/Provincial as well as a Central Legislature 3
4 Nature of Succession Law A single succession law applies throughout the country Existence of plural legislations where state/ province has the autonomy to legislate on succession laws Religion or Community based succession law Succession is governed by central laws however local law may govern successions regarding agriculture and farming Succession law applies through the metropolitan territory but special rules exist for overseas territories and overseas collectivities Countries Argentina, Brazil, Germany and Venezuela Australia, Canada, Mexico, UK and USA India and Spain Austria, Germany and India France and Denmark Broad classification: Law of ownership (identify assets that are owned by the deceased upon his death) Matrimonial Law Contract law (succession pacts) Succession laws are considered operational predominantly through two modes namely: - Direct transmission - Indirect transmission 4
5 Situation Principle of direct transmission from deceased to the heirs. Transfer is not assimilated to a sale and hence not regarded as a taxable event for capital gains purposes. Principle of indirect transmission under which assets, rights and obligations are first transferred from the deceased person to a personal representative and then the net assets are transferred to the legal heirs Countries France, Argentina,Belgium, Brazil, Chinese Taipei, Colombia, Czech Republic, Germany, Greece, Hungary, Korea, Italy, Japan, Luxembourg, Mexico, Peru, Poland, Switzerland and Uruguay Denmark,Norway, Sweden and all common law countries (Canada, Bhutan, New Zealand, Hongkong, Ireland etc) Taxation based on the domicile of the deceased In some countries residence must have been maintained for a certain period. (5 years in the case of Netherlands) In common law countries (also in Belgium, France, Ireland, Israel, Korea, Luxembourg and Ukraine), scope of residence or domicile based taxation is restricted only to immovable properties 5
6 Nationality based taxation (Croatia, Chinese Taipei, Germany, Greece, Italy, Japan, Poland, Portugal, Spain and Serbia) Multiple parameters being adopted by central and state legislature Type of Tax Description Countries Inheritance tax (IHT) Tax levied on the legal heir Luxembourg,, Czech Republic etc Estate tax (ETA) Tax levied on the estate France, Greece, Hungary, Italy, Norway, Poland, Netherlands, Chile, Croatia etc Capital gains Tax ETA and IHT Gift tax (in addition to IHT and ETA) Tax levied on transfer of estate ETA is levied based on the value of the estate Tax on receipt of estate without consideration Russia, Ukraine etc UK, Belgium, Chinese Taipei, Korea and Denmark France, Germany, Luxembourg, Italy, USA etc 6
7 Estate tax or Inheritance Tax is a tax levied at the time of death or succession. Such tax is levied on the value of estate of the deceased or donor. Some legislations levy capital gains tax at the time transfer of estate to successor. 7
8 Estate Duty Act 1953 was repealed w.e.f 16 th March 1985 Gift Tax Act was abolished by Finance Act 1998 w.e.f 1 st of October Finance Act (2)2004 introduced Sec 56(2)(v) for taxation of gifts subject to exceptions Wealth Tax is 1% on Net Wealth exceeding Rs 30 lacs. Hence there is no estate or inheritance tax payable in India Wealth of 1% is leviable on net wealth exceeding Rs 100 lacs effective (as per DTC) 8
9 India is a safe place of Domicile There is no tax on succession hence it is always suggested to have India as an investment intermediary Investment outside India: Remittance up to USD 2,00,000 p.a permitted for specified transactions Specified transactions include: Investment in Foreign Securities Transfer of immovable property outside India Other respective guidelines need to be adhered at the time of investment. 9
10 Investment in foreign securities permitted for a resident in India and a company registered in India. The investee company must be listed and fulfill the conditions prescribed. Investment subject to limits prescribed. ODI possible through a Joint Venture of Wholly Owned Subsidiary outside India Total financial commitment of the Indian Party not to exceed 400% of net worth (200% in case of partnership firms) Investments in Nepal can be made only in Rupees Investment in Pakistan is not permitted 10
11 JV or WOS must be engaged in a bonafide business Indian Party (IP) is not mentioned in any caution/ defaulters list of RBI. IP routes all the transactions through an authorised dealer and fulfills the compliance procedures prescribed. Investment through miscellaneous remittance of upto USD 200,000 permissible per year per resident individual. 11
12 Permissible through proceeds in RFC account. Permissible if foreign exchange was earned when assessee was a resident outside India. Miscellaneous remittance route adopted in most circumstances. In any other case, approval is required. 12
13 Domicile/citizen based estate taxation. Estate includes all tangible and intangible property. Assets considered at retail value on succession Estate Tax Rate : 55% (proposed for 2011) Estate tax applies on: Assets at US US Citizens Non resident citizens Non resident and non citizens Full / proportionate tax credit is available if there is another estate transfer within 10 years. 13
14 Direct legacy to a spouse who is a US citizen is exempt. Basic exemption of USD 1.0 MM (2011 onwards)- reduced from USD 3.5 MM in Estate tax was temporarily repealed for the year 2010 Year Exclusion Amount 2001 $675,000 55% 2002 $1 million 50% 2003 $1 million 49% 2004 $1.5 million 48% 2005 $1.5 million 47% 2006 $2 million 46% 2007 $2 million 45% 2008 $2 million 45% 2009 $3.5 million 45% Max/Top tax rate 2010 * Repealed * 0% * 2011 $1 million 55% 14
15 There is no estate tax or inheritance tax on death One of the few OECD countries which does not have an estate tax However capital gains tax may arise on death or succession Roll over benefits are available on capital gains arising on death Roll over benefits not available for tax advantaged entities (tae) Tae includes individual or entity who is a foreign resident In case of assets held abroad, succeeded by a non resident capital gains tax shall arise on death - Possibility of double taxation cannot be ruled out (refer illustration) 15
16 . Australian Resident (A) Owns a property in France Capital gains tax shall apply on the deceased final tax return Property inherited by a non resident Australian on death of (A) Estate taxes apply on death or absence of an individual Rate of tax varies from 5% to 45% based on the value of the transfer and relationship Estate tax applies on all the following situations: Deceased is a French resident Successor is a French resident Property is in France 16
17 Succession of family business has exemptions upto 75% of the estate value subject to conditions Capital gains tax also arises on deathhowever the same is deferred in most circumstances Huge possibility of double taxation in case of assets held abroad. Huge possibility of double taxation in case of assets held abroad. Belgian Resident (A) Owns a shares of a French Company Estate / Gift tax shall apply in both France and Belgium Property inherited by a French resident on death of (A) 17
18 There are no estate and inheritance taxes in Canada. Death and consequent movement of property is regarded as transfer in the hands of the deceased Exceptions include transfer to a spouse/ spousal trust Capital gains arises on death of an individual Taxes are levied by Provincial and Federal Governments Rates of taxation of capital gains vary from: Federal tax : 15% to 29% Provincial tax : 4% to 17% Tax credit is available on capital gains paid abroad on inheritence 18
19 No credit is available for ET/ IHT paid abroad. Possibility of double taxation is very high DTAA available with US and France. Hague Convention on the Law Applicable to Succession to the Estates of Deceased Persons (1989) Conflicts of Laws relating to the Form of Testamentary Dispositions (1961) Convention Concerning the International Administration of the Estates of Deceased Persons (1973) 19
20 UNIDROIT Convention providing a Uniform Law on the Form of an International Will (1973) Regional conventions between Nordic countries (1934) and certain Latin American countries 20
21 Private Investment Trust Investment holding companies Multi - Layered holding Structuring investment options The best planning structure is possible prior to making an investment Trusts are regarded as separate legal entities in most tax jurisdictions Family members are beneficiaries Death of a members reduces the number of beneficiaries Multiple trusts can be created to suite domestic regulations Estate and inheritance tax can be avoided 21
22 Private Specific Trusts : Shares of the members are determinate Private Discretionary Trusts: Shares of the members are not determinate. Trust has Business Income Trust does not have Business Income Maximum Marginal Rate: 30% Tax rate applicable to each beneficiary Alternatively- Assessing Officer can assess the income in the hands of the beneficiaries At rates of an AoP if: -Trust is declared by Will - It is exclusively for the benefit of any dependant relative - The trust is the only trust declared by the settlor 22
23 . Trust has Business Income Trust does not have Business Income At rates of an AoP if: -Trust is declared by Will - It is exclusively for the benefit of any dependant relative or - The trust is the only trust declared by the settlor Maximum Marginal Rate At rates of an AoP if: -The income of none of the beneficiaries does not exceed basic exemption limit -None of the beneficiaries are beneficiaries in any other trust -Trust is declared by Will - It is exclusively for the benefit of any dependant relative - The trust is the only trust declared by the settlor No tax shall be assessable on the grantor However where the trust is for the immediate or deferred of the spouse and minor child the individual shall be liable to tax to the extent of their share of income from the trust. 23
24 Income Slab Upto Rs 1,60,000 Tax Rates Nil Above Rs 1,60,000 upto Rs 5,00,000 10% Above Rs 5,00,000 upto Rs 8,00,000 20% Above Rs 8,00,000 30% Note: - Rates as applicable for Previous year Cess of 3% shall be levied over and above the tax rates -Where shares of members are indeterminate, the trust shall be chargeable to tax at maximum marginal rate or at such higher rates Where shares are determinate- Sec 67A: Share of each beneficiary shall be proportionately computed Income shall be part of the personal income under the respective heads of income 24
25 Situation Income Taxability AoP is taxed at Maximum Marginal Rate AoP taxed as per slab rates AoP is not liable for tax Not included in total income No tax liability Included in total income No tax liability Included in total income Tax shall apply. Family in India Forms an Investment Trust in India or abroad Multiple trusts can be created for investments in different jurisdictions Makes an Investment abroad in the name of the trust 25
26 Investment is made in the shares of a Holding Company which in turns makes an investment in the ultimate asset. Holding company should be located in a country where IHT/ ET is minimal or absent eg: India In the event of death of a share holder, the shares are transferred to the nominee or legal heir of the deceased in the country of incorporation of the holding company. The legal owner of the asset still remains the holding company. 26
27 Executed in 2009 Family in India Invests in shares of an Indian Holding Company US, at present, does not have the Look Through provisions for Estate Taxes Makes an Investment at US Benefits: Ownership remains with the Indian company irrespective of death of the promoters No estate tax upon succession Disadvantages: Huge capital gains liability if the asset is ultimately sold at the US 27
28 Situs of taxation (source vs residence) Economic double taxation (IHT / ETA vs WT) Taxation of transfer from administrator (Canada) Varying definitions of spouse in different legislations 28
29 Coordination with Global tax professionals Estate planning to be undertaken prior to investment Constant change in estate tax laws and limits Planning holds good for laws prevailing at the time of structuring. Planning comes at a cost ie certain benefits are restricted to estate tax payers eg: US Pluralism of succession laws of both countries 29
30 Top management salaried employees (CFOs, CEOs, CIOs ) Medium and Large scale exporters and importers Industrialists, Film stars, Directors Other High Net worth Individual (net worth exceeding Rs 20 crores) Identify the possible tax cost in India Discuss with the destination professionals Manage the complete foreign exchange compliance at the time of investment Explore the possibility of ODI and ECB (outside India for investment in a third country) Maintain the structure and alter to suit changing tax laws. 30
31 . Legal Advisor Abroad Financial Advisor Abroad Indian CA Indian Client and his family Legal Counsel in India Activity Determination of Taxation Cost in India Basis of Payout Per Opinion/ Transaction Determination of FEMA regulations Structuring the transaction in consultation with foreign professionals Per Opinion/ Transaction Fixed fee plus per hour engagement if it exceeds certain stipulated hours agreed upon Maintaining the structure including regulatory updates Fixed Annual fee 31
32 32
Reporting practices for domestic and total debt securities
Last updated: 27 November 2017 Reporting practices for domestic and total debt securities While the BIS debt securities statistics are in principle harmonised with the recommendations in the Handbook on
More informationSetting up in Denmark
Setting up in Denmark 6. Taxation The Danish tax system for individuals rests on the global taxation principle. The principle holds that the income of individuals and companies with full tax liability
More informationOverview of Transfer Pricing Regulations. CA Akshay Kenkre
Overview of Transfer Pricing Regulations CA Akshay Kenkre 1 What is Transfer Pricing What is Transfer Price? A Price at which one person transfers physical goods, services, tangible or/ and intangibles
More informationDefinition of international double taxation
Definition of international double taxation Juridical double taxation: imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical
More informationTAXATION OF TRUSTS IN ISRAEL. An Opportunity For Foreign Residents. Dr. Avi Nov
TAXATION OF TRUSTS IN ISRAEL An Opportunity For Foreign Residents Dr. Avi Nov Short Bio Dr. Avi Nov is an Israeli lawyer who represents taxpayers, individuals and entities. Areas of Practice: Tax Law,
More informationCorrigendum. OECD Pensions Outlook 2012 DOI: ISBN (print) ISBN (PDF) OECD 2012
OECD Pensions Outlook 2012 DOI: http://dx.doi.org/9789264169401-en ISBN 978-92-64-16939-5 (print) ISBN 978-92-64-16940-1 (PDF) OECD 2012 Corrigendum Page 21: Figure 1.1. Average annual real net investment
More informationApproach to Employment Injury (EI) compensation benefits in the EU and OECD
Approach to (EI) compensation benefits in the EU and OECD The benefits of protection can be divided in three main groups. The cash benefits include disability pensions, survivor's pensions and other short-
More informationSan Francisco Retiree Health Care Trust Fund Education Materials on Public Equity
M E K E T A I N V E S T M E N T G R O U P 5796 ARMADA DRIVE SUITE 110 CARLSBAD CA 92008 760 795 3450 fax 760 795 3445 www.meketagroup.com The Global Equity Opportunity Set MSCI All Country World 1 Index
More information(of 19 March 2013) Valid from 1 January A. Taxpayers
Leaflet. 29/460 of the Cantonal Tax Office on withholding taxes applicable to pension benefits under private law for persons without domicile or residence in Switzerland (of 19 March 2013) Valid from 1
More informationFinancial wealth of private households worldwide
Economic Research Financial wealth of private households worldwide Munich, October 217 Recovery in turbulent times Assets and liabilities of private households worldwide in EUR trillion and annualrate
More informationSTOXX EMERGING MARKETS INDICES. UNDERSTANDA RULES-BA EMERGING MARK TRANSPARENT SIMPLE
STOXX Limited STOXX EMERGING MARKETS INDICES. EMERGING MARK RULES-BA TRANSPARENT UNDERSTANDA SIMPLE MARKET CLASSIF INTRODUCTION. Many investors are seeking to embrace emerging market investments, because
More informationThird Revised Decision of the Council concerning National Treatment
Third Revised Decision of the Council concerning National Treatment OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD
More informationGuide to Treatment of Withholding Tax Rates. January 2018
Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep
More informationSources of Government Revenue in the OECD, 2016
FISCAL FACT No. 517 July, 2016 Sources of Government Revenue in the OECD, 2016 By Kyle Pomerleau Director of Federal Projects Kevin Adams Research Assistant Key Findings OECD countries rely heavily on
More informationVinodh & Muthu. Tax Alert. Insight. Chartered Accountants. Country by Country Reporting & Master File
Vinodh & Muthu Chartered Accountants Tax Alert Country by Country Reporting & Master File Insight The Organisation for Economic Cooperation and Development ( OECD ) report on Action 13 of Base Erosion
More informationThin Capitalization A Detailed Study
Thin Capitalization A Detailed Study C.A. Divakar Vijayasarathy This paper is a copyright of Divakar Vijayasarathy & Associates. The author and the firm expressly disown their liability on any consequence
More informationCORPORATE CATALYST (INDIA) PVT LTD. (in joint venture with SCS Global) Setting up >> business presence in india
CORPORATE CATALYST (INDIA) PVT LTD (in joint venture with SCS Global) Setting up >> business presence in india CORPORATE TAX >> CORPORATE TAX IS PAID BY COMPANIES, BRANCHES AND PROJECT OFFICES OF OVERSEAS
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org). wide Regulated Open-ended Fund Assets and Flows Trends
More informationFinancial law reform: purpose and key questions
Conference on Cross-Jurisdictional Netting and Global Solutions Update on Netting in Asia May 12, 2011 London School of Economics and Political Science Peter M Werner Senior Director ISDA pwerner@isda.org
More informationAPA & MAP COUNTRY GUIDE 2017 CANADA
APA & MAP COUNTRY GUIDE 2017 CANADA Managing uncertainty in the new tax environment CANADA KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org). Worldwide Regulated Open-ended Fund Assets and Flows Trends
More informationFOREIGN ACTIVITY REPORT
FOREIGN ACTIVITY REPORT SECOND QUARTER 2012 TABLE OF CONTENTS Table of Contents... i All Securities Transactions... 2 Highlights... 2 U.S. Transactions in Foreign Securities... 2 Foreign Transactions in
More informationRecommendation of the Council on Tax Avoidance and Evasion
Recommendation of the Council on Tax Avoidance and Evasion OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD Legal Instrument
More information8-Jun-06 Personal Income Top Marginal Tax Rate,
8-Jun-06 Personal Income Top Marginal Tax Rate, 1975-2005 2005 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 1989 1988 Australia 47% 47% 47% 47% 47% 47% 47% 47% 47% 47% 47% 48% 49% 49% Austria
More informationSetting up >> business presence in india.
Setting up >> business presence in india www.asa.in CORPORATE TAX >> CORPORATE TAX IS PAID BY COMPANIES, BRANCHES AND PROJECT OFFICES OF OVERSEAS COMPANIES ON PROFITS AND OTHER INCOME COMPANY RATE (%)
More informationFOREWORD. Cayman Islands
2015/16 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationSources of Government Revenue in the OECD, 2014
FISCAL FACT Nov. 2014 No. 443 Sources of Government Revenue in the OECD, 2014 By Kyle Pomerleau Economist Key Findings OECD countries rely heavily on consumption taxes, such as the value added tax, and
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationIMPORTANT TAX INFORMATION
00126803 IMPORTANT TAX INFORMATION Dear Hartford Funds Shareholder: The following information about your enclosed 1099-DIV from Hartford Funds should be used when preparing your 2014 tax return. The information
More informationGlobal Business Barometer April 2008
Global Business Barometer April 2008 The Global Business Barometer is a quarterly business-confidence index, conducted for The Economist by the Economist Intelligence Unit What are your expectations of
More informationEQUITY REPORTING & WITHHOLDING. Updated May 2016
EQUITY REPORTING & WITHHOLDING Updated May 2016 When you exercise stock options or have RSUs lapse, there may be tax implications in any country in which you worked for P&G during the period from the
More informationKPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX
KPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX B KPMG s Individual Income Tax and Social Security Rate Survey 2009 KPMG s Individual Income Tax and Social Security Rate Survey 2009
More informationSources of Government Revenue in the OECD, 2018
FISCAL FACT No. 581 Mar. 2018 Sources of Government Revenue in the OECD, 2018 Amir El-Sibaie Analyst Key Findings In 2015, OECD countries relied heavily on consumption taxes, such as the value-added tax,
More informationSources of Government Revenue in the OECD, 2017
FISCAL FACT No. 558 Aug. 2017 Sources of Government Revenue in the OECD, 2017 Amir El-Sibaie Analyst Key Findings: OECD countries rely heavily on consumption taxes, such as the value-added tax, and social
More informationINDIA GREECE NETHERLANDS
HOLDING STRUCTURES Updated information JULY 2013 INDEX ANDORRA BULGARIA CYPRUS INDIA GREECE NETHERLANDS SPAIN URUGUAY GERMANY The content of this newsletter has been written or gathered by ANTEA Alliance
More informationThe Global Equity Matrix
The Global Equity Matrix Cash Awards, Employee Stock Options, Stock Purchase Rights, Restricted Stock and Restricted Stock Units Argentina Denmark Israel Peru Sweden Australia Egypt Italy Philippines Switzerland
More informationValid from 1 January A. Taxpayers
Leaflet. 29/410 of the Cantonal Tax Office on withholding taxes applicable to pension benefits under public law for persons without domicile or in Switzerland (of 19 March 2013) Valid from 1 January 2013
More informationCOUNTRY COST INDEX JUNE 2013
COUNTRY COST INDEX JUNE 2013 June 2013 Kissell Research Group, LLC 1010 Northern Blvd., Suite 208 Great Neck, NY 11021 www.kissellresearch.com Kissell Research Group Country Cost Index - June 2013 2 Executive
More informationSources of Government Revenue across the OECD, 2015
FISCAL FACT Apr. 2015 No. 465 Sources of Government Revenue across the OECD, 2015 By Kyle Pomerleau Economist Key Findings OECD countries rely heavily on consumption taxes, such as the value added tax,
More informationFOREWORD. Jersey. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationGross to net salary of a local executive and total cost to employer comparison for selected countries
Gross to net salary of a local executive and total cost to employer comparison for selected countries Married, two dependant children All the numbers are in EURO Country Gross Salary Employee Income Net
More informationDIVERSIFICATION. Diversification
Diversification Helps you capture what global markets offer Reduces risks that have no expected return May prevent you from missing opportunity Smooths out some of the bumps Helps take the guesswork out
More informationSummary 715 SUMMARY. Minimum Legal Fee Schedule. Loser Pays Statute. Prohibition Against Legal Advertising / Soliciting of Pro bono
Summary Country Fee Aid Angola No No No Argentina No, with No No No Armenia, with No No No No, however the foreign Attorneys need to be registered at the Chamber of Advocates to be able to practice attorney
More informationGlossary of Defined Terms
Glossary of Defined Terms Glossary History Change Date April 2007 July 2007 Description of Changes Initial Launch Amendment of definition of administrator(s) Glossary History July 2007 Page 1 of 1 A Accredited
More informationA. Definitions and sources of data
Poland A. Definitions and sources of data Data on foreign direct investment (FDI) in Poland are reported by the National Bank of Poland (NBP), the Polish Agency for Foreign Investment (PAIZ) and the Central
More informationFinland Country Profile
Finland Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Finland EU Member State Double Tax Treaties With: Argentina Armenia Australia
More informationAPA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
More informationDoes One Law Fit All? Cross-Country Evidence on Okun s Law
Does One Law Fit All? Cross-Country Evidence on Okun s Law Laurence Ball Johns Hopkins University Global Labor Markets Workshop Paris, September 1-2, 2016 1 What the paper does and why Provides estimates
More informationINTERNATIONAL JOURNAL OF RESEARCH AND ANALYSIS VOLUME 5 ISSUE 2 ISSN
CRITICAL ANALYSIS ON DOUBLE TAXATION AVOIDANCE AGREEMENT **AASTHA SUMAN & HIMANSHU SHUKLA The DTAA, or Double countries) so that taxpayers can avoid paying double taxes on their income earned from the
More informationThe Case for Fundamental Tax Reform: Overview of the Current Tax System
The Case for Fundamental Tax Reform: Overview of the Current Tax System Sources of Federal Receipts Projected for 2016 Excise Taxes 2.9% Estate & Gift Taxes 0.6% Corporate Income Taxes 9.8% Other Taxes
More informationQuarterly Investment Update First Quarter 2018
Quarterly Investment Update First Quarter 2018 Dimensional Fund Advisors Canada ULC ( DFA Canada ) is not affiliated with [insert name of Advisor]. DFA Canada is a separate and distinct company. Market
More informationAA& Associates. Setting Up >> LLP. business presence in india.
LLP AA& Associates chartered accountants (A member firm of NIS Global) Setting Up >> business presence in india www.asa.in CORPORATE TAX >> CORPORATE TAX IS PAID BY COMPANIES, BRANCHES AND PROJECT OFFICES
More informationDeclaration on Environmental Policy
Declaration on Environmental Policy OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD Legal Instrument and may contain
More informationPENTA CLO 2 B.V. (the "Issuer")
THIS NOTICE CONTAINS IMPORTANT INFORMATION OF INTEREST TO THE REGISTERED AND BENEFICIAL OWNERS OF THE NOTES (AS DEFINED BELOW). IF APPLICABLE, ALL DEPOSITARIES, CUSTODIANS AND OTHER INTERMEDIARIES RECEIVING
More informationSlovakia Country Profile
Slovakia Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Slovakia EU Member State Double Tax Treaties Yes With: Australia Austria Belarus
More informationSummary of key findings
1 VAT/GST treatment of cross-border services: 2017 survey Supplies of e-services to consumers (B2C) (see footnote 1) Supplies of e-services to businesses (B2B) 1(a). Is a non-resident 1(b). If there is
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationRecommendation of the Council on the Implementation of the Polluter-Pays Principle
Recommendation of the Council on the Implementation of the Polluter-Pays Principle OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org) Worldwide Investment Fund Assets and Flows Trends in the
More informationProfile and Distribution of Capital Taxes
+ Profile and Distribution of Capital Taxes April 2018 Statistics & Economic Research Branch Profile and Distribution of Capital Taxes The author is Martina Shirran, Statistics & Economic Research Branch
More informationTurkey s Saving Deficit Issue From an Institutional Perspective
Turkey s Saving Deficit Issue From an Institutional Perspective Engin KURUN, Ph.D CEO, Ziraat Asset Management Oct. 25th, 2011 - Istanbul 1 PRESENTATION Household and Institutional Savings Institutional
More information10 GREAT MYTHS OF GLOBAL CIVIL SOCIETY
10 GREAT MYTHS OF GLOBAL CIVIL SOCIETY Lester M. Salamon Johns Hopkins University Japan Commerce Association of Washington October 21, 2013 THE GLOBAL ASSOCIATIONAL REVOLUTION FOR-PROFIT SECTOR CIVIL SOCIETY
More informationThe Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA) In the period January - April 2017 Bulgarian exports to the EU increased by 8.6% 2016 and amounted to 10 418.6 Million BGN
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA) In the period January - May 2017 Bulgarian exports to the EU increased by 10.8% 2016 and added up to 13 283.0 Million BGN (Annex,
More informationPart B STATEMENT OF ADDITIONAL INFORMATION
Part B STATEMENT OF ADDITIONAL INFORMATION SIT LARGE CAP GROWTH FUND, INC. SNIGX SIT MID CAP GROWTH FUND, INC. NBNGX SIT MUTUAL FUNDS, INC, comprised of: SIT BALANCED FUND SIBAX SIT DIVIDEND GROWTH FUND,
More informationStatistical annex. Sources and definitions
Statistical annex Sources and definitions Most of the statistics shown in these tables can be found as well in several other (paper or electronic) publications or references, as follows: the annual edition
More informationWithholding Tax Rate under DTAA
Withholding Tax Rate under DTAA Country Albania 10% 10% 10% 10% Armenia 10% Australia 15% 15% 10%/15% [Note 2] 10%/15% [Note 2] Austria 10% Bangladesh Belarus a) 10% (if at least 10% of recipient company);
More informationRegistration of Foreign Limited Partnerships in the Cayman Islands
Registration of Foreign Limited Partnerships in the Cayman Islands Preface This publication has been prepared for the assistance of those who are considering registration of a foreign limited partnership
More informationQuarterly Investment Update First Quarter 2017
Quarterly Investment Update First Quarter 2017 Market Update: A Quarter in Review March 31, 2017 CANADIAN STOCKS INTERNATIONAL STOCKS Large Cap Small Cap Growth Value Large Cap Small Cap Growth Value Emerging
More informationInvestor Profile. Irish Corporate 1 I N V E S T O R P R O F I L E
Investor Profile Irish Corporate 2017 1 I N V E S T O R P R O F I L E Disclaimer The information provided in this publication is for general information purposes only and is valid as at January 1, 2017.
More informationINTESA SANPAOLO S.p.A. INTESA SANPAOLO BANK IRELAND p.l.c. 70,000,000,000 Euro Medium Term Note Programme
PROSPECTUS SUPPLEMENT INTESA SANPAOLO S.p.A. (incorporated as a società per azioni in the Republic of Italy) as Issuer and, in respect of Notes issued by Intesa Sanpaolo Bank Ireland p.l.c., as Guarantor
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationOther Tax Rates. Non-Resident Withholding Tax Rates for Treaty Countries 1
Other Tax Rates Non-Resident Withholding Tax Rates for Treaty Countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15
More informationInvestor Profile. UK Corporate
Investor Profile UK Corporate 2017 Disclaimer The information provided in this publication is for general information purposes only and is valid as at January 1, 2017. Any changes to legislation or treaties
More informationWHY UHY? The network for doing business
The network for doing business the network for doing business UHY has over 6,800 professionals to choose from trusted advisors and consultants operating in more than 250 business centres, based in 81 countries
More informationInternational Statistical Release
International Statistical Release This release and additional tables of international statistics are available on efama s website (www.efama.org). Worldwide Investment Fund Assets and Flows Trends in the
More informationDOMESTIC CUSTODY & TRADING SERVICES
Pricing Structure DOMESTIC CUSTODY & TRADING SERVICES A flat custody fee of 20bps per account type per year is applicable to all holdings and cash, the custody fee is collected each month but will be capped
More informationNon-resident withholding tax rates for treaty countries 1
Non-resident withholding tax rates for treaty countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15 15/25 Armenia
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationLex Mundi European Union: Accession States Tax Guide. BULGARIA Penkov, Markov & Partners
Lex Mundi European Union: Accession States Tax Guide BULGARIA Penkov, Markov & Partners CONTACT INFORMATION: Svetlin Adrianov Penkov, Markov & Partners Tel: 359.2.9713935 - Fax: 359.2.9711191 E-mail: lega@bg400.bg
More informationPREDICTING VEHICLE SALES FROM GDP
UMTRI--6 FEBRUARY PREDICTING VEHICLE SALES FROM GDP IN 8 COUNTRIES: - MICHAEL SIVAK PREDICTING VEHICLE SALES FROM GDP IN 8 COUNTRIES: - Michael Sivak The University of Michigan Transportation Research
More informationTAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF REGULATIONS No. 3) (JERSEY) ORDER 2017
Taxation (Implementation) (Convention on Mutual Regulations No. 3) (Jersey) Order 2017 Article 1 TAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF
More informationControlled Foreign Corporation
Controlled Foreign Corporation Certificate Course on International Taxation, Chennai Arpit Jain Director International Tax Background Spread of CFC legislation across the world in last 30-40 years US-perhaps
More informationGlobal Tax Reset Transfer Pricing Documentation Summary. February 2018
Global Tax Reset Transfer Pricing Summary February 2018 Global Tax Reset Transfer Pricing Summary Overview The Global Tax Reset Transfer Pricing Summary ( Guide ) compiles essential country-by-country
More informationInvestor Profile. UK Pension Fund
Investor Profile UK Pension Fund 2017 Disclaimer The information provided in this publication is for general information purposes only and is valid as at January 1, 2017. Any changes to legislation or
More informationQ&A. 1. Q: Why did the company feel the need to move to Ireland?
Q&A 1. Q: Why did the company feel the need to move to Ireland? A: As we continue to grow the international portion of our business, we believe that moving to a member state of the European Union (EU)
More informationSpain Country Profile
Spain Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Spain EU Member State Double Tax Treaties With: Albania Algeria Andorra Argentina
More informationOpen Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems. 5 October 2017
Open Day 2017 Clearstream execution-to-custody integration Valentin Nehls / Jan Willems 5 October 2017 Deutsche Börse Group 1 Settlement services: single point of access to cost-effective, low risk and
More informationTax Desk Book. ISRAEL S. Horowitz & Co
Introduction Tax Desk Book ISRAEL S. Horowitz & Co CONTACT INFORMATION: Leor Nouman Ophir Kaplan S. Horowitz & Co. 31 Ahad Ha'am Street Tel-Aviv 65202 Israel (+972-3-5670666) leorn@s-horowitz.co.il www.s-horowitz.com
More informationRevenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings Page 1 of 21 Table of Contents 1. Introduction...3 2. Overview of Council Directive (EU)
More informationDouble tax considerations on certain personal retirement scheme benefits
www.pwc.com/mt The elimination of double taxation on benefits paid out of certain Maltese personal retirement schemes February 2016 Double tax considerations on certain personal retirement scheme benefits
More informationSwiss Global Finance. Facts and Figures
Swiss Global Finance Facts and Figures Latin America Bilateral Economic Relations Switzerland s Main Trading Partners in Latin America Share of Total Goods Exports (in % of total Swiss exports to Latin
More informationFOREWORD. Estonia. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationALI-ABA Course of Study International Trust and Estate Planning. August 16-17, 2007 Chicago, Illinois
35 ALI-ABA Course of Study International Trust and Estate Planning August 16-17, 2007 Chicago, Illinois Basic U.S. Transfer and Income Tax Rules Applicable to Non-Resident Aliens By Virginia F. Coleman
More informationCRS Self-Certification Form for Controlling Persons
Instructions Please read these instructions carefully before completing the form. Citi offices located in countries that have adopted the Common Reporting Standard (CRS) are required to collect certain
More informationBETTER POLICIES FOR A SUCCESSFUL TRANSITION TO A LOW-CARBON ECONOMY
BETTER POLICIES FOR A SUCCESSFUL TRANSITION TO A LOW-CARBON ECONOMY Rintaro Tamaki Deputy Secretary-General, OECD International Forum for Sustainable Asia and the Pacific (ISAP)1 Yokohama, July 1 Four
More informationWithholding tax rates 2016 as per Finance Act 2016
Withholding tax rates 2016 as per Finance Act 2016 Sr No Country Dividend Interest Royalty Fee for Technical (not being covered under Section 115-O) Services 1 Albania 10% 10% 10% 10% 2 Armenia 10% 10%
More informationPortugal Country Profile
Portugal Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Portugal EU Member State Double Tax Treaties Yes With: Algeria Andorra (a)
More information15 Popular Q&A regarding Transfer Pricing Documentation (TPD) In brief. WTS strong presence in about 100 countries
15 Popular Q&A regarding Transfer Pricing Documentation (TPD) Contacts China Martin Ng Managing Partner Martin.ng@worldtaxservice.cn + 86 21 5047 8665 ext.202 Xiaojie Tang Manager Xiaojie.tang@worldtaxservice.cn
More information