Some Austrian tax aspects relevant for individuals moving to Austria
|
|
- Kevin Allen Collins
- 6 years ago
- Views:
Transcription
1 MEMORANDUM From: Niklas Schmidt Re: 1. General 29 August 2014 Some Austrian tax aspects relevant for individuals moving to Austria 1.1 Austria is a landlocked country in Central Europe with a population of approx. 8.5m. It is bordered by the Czech Republic and Germany to the North, Hungary and the Slovak Republic to the East, Slovenia and Italy to the South, and Switzerland and Liechtenstein to the West. Austria's territory covers approx. 32,400 square miles, and is highly mountainous due to its location within the Alps. Historically speaking, the origins of modern-day Austria date back to the time of the Habsburg empire. WOLF THEISS Rechtsanwälte Schubertring Vienna Austria T F wien@wolftheiss.com WOLF THEISS Rechtsanwälte GmbH & Co KG UID: ATU ; DVR: ADVM: P130664; FN b FG: HG Vienna; Seat: Vienna 1.2 Austria has a GDP (PPP) per capita of approx. USD 43,800, making it one of the richest countries in the world. Major industries in Austria are tourism, banking, foodstuffs, luxury commodities, mechanical engineering, steel construction, chemicals and vehicle manufacturing. 1.3 Austria is a member in particular of the EU (including the Eurozone), the OECD and the WTO. 1.4 In the worldwide ranking of cities regarding quality of living conducted by the HR consultancy Mercer in 2014, Vienna is in the first place, and has consistently been among the top three in the past. 1.5 The Republic of Austria is composed of nine federal provinces. Austrian taxes are mostly levied on a federal level. No state or provincial tax is levied on an individual's income. Federal taxes are administered by the Austrian Minister of Finance (Bundesministerium für Finanzen; cf. and its subordinate tax offices. 1.6 The main sources of tax law are firstly various tax acts enacted by the Austrian Parliament (e.g., the Austrian Income Tax Act [Einkommensteuergesetz], the Austrian Corporate Income Tax Act [Körperschaftsteuergesetz], the Austrian Value Added Tax Act [Umsatzsteuergesetz] and the Austrian Federal Fiscal Procedures Act [Bundesabgabenordnung]). Secondly, the Austrian Minister of Finance may issue ordinances which have to be in line with tax acts, but may further determine ALBANIA AUSTRIA BOSNIA & HERZEGOVINA BULGARIA CROATIA CZECH REPUBLIC HUNGARY POLAND ROMANIA SERBIA SLOVAK REPUBLIC SLOVENIA UKRAINE Our operations in the various locations comply with the requirements of the relevant local law and local bar rules, including cooperation with independent local attorneys.
2 their content; these are binding on the taxpayers, the tax administration and the courts. Thirdly, the Austrian Minister of Finance may issue guidelines (e.g., the Austrian Income Tax Guidelines [Einkommensteuerrichtlinien]), which are, however, only binding on the tax offices (i.e., the first instance). In Austria precedents do not have binding authority for future cases, but especially cases decided by the Austrian Supreme Administrative Court (Verwaltungsgerichthof) in practice give guidance on how tax acts have to be applied. 2. Income tax 2.1 For income tax purposes Austrian tax law distinguishes between residents and non-residents: Individuals having a domicile (Wohnsitz) and/or their habitual abode (gewöhnlicher Aufenthalt) in Austria are considered as residents and are subject to unlimited income tax liability in Austria on their worldwide income (cf. sec. 1(2) of the Austrian Income Tax Act). All other individuals (i.e., individuals neither having a domicile nor their habitual abode in Austria) are considered as nonresidents and are subject to limited income tax liability only on their Austrian-source income (cf. sec. 1(3) of the Austrian Income Tax Act). Citizenship is thus not decisive for purposes of tax residency. 2.2 A domicile for tax purposes is maintained where a taxpayer has a dwelling place under circumstances which permit the conclusion that the taxpayer intends to keep and use it (cf. sec. 26(1) of the Austrian Federal Fiscal Procedures Act). Such dwelling place must consist of one or more rooms which are furnished for the purpose of living there regularly. In most cases a dwelling place consists of rooms which are either owned or rented by the respective taxpayer. However, not the legal title to the dwelling place is decisive, but rather the factual possibility to make use thereof. Thus, also a hotel room or a holiday home can qualify as a domicile. Just having a dwelling place is not enough; in addition, there have to be circumstances which permit the conclusion that the taxpayer intends to keep and use it for a longer period of time. A residence notification (Meldung) to the respective municipal authorities may for example serve as an indication thereof. 2.3 An habitual abode for tax purposes is maintained where a taxpayer stays under circumstances which permit the conclusion that the taxpayer intends to dwell there not only temporarily; staying in Austria for more than six months irrefutably leads to an habitual abode, even for the first six months (cf. sec. 26(2) of the Austrian Federal Fiscal Procedures Act). Whereas a taxpayer can have more than one domicile, it is never possible to have more than one habitual abode. It is not necessary to stay in the same municipality; rather dwelling somewhere in Austria is decisive. Temporary stops in Austria do not result in an habitual abode in Austria, e.g., in case of shortterm visits. Furthermore, repeated short-term stays in Austria are generally not to be added up for the purposes of the six months' clause. 2.4 However, apart from the statutory rules of the Austrian Income Tax Act attention also has to be paid to an ordinance regarding secondary residences issued by the Austrian Minister of Finance. Pursuant thereto, in case of taxpayers whose center of vital interests is outside of Austria for more than five calendar years, an Austrian dwelling place qualifies as a domicile only in such years in which the dwelling place is used (alone or together with other Austrian dwelling places) 2
3 for more than 70 calendar days. This rule is only applicable if the taxpayer keeps a list of the days during which the dwelling place is used. 2.5 An individual's income is subject to progressive income tax, with the following rate bands applying: (i) up to and including EUR 11,000: 0%; (ii) over EUR 11,000 up to and including EUR 25,000: 36.5%; (iii) over EUR 25,000 up to and including EUR 60,000: 43.21%; and (iv) over EUR 60,000: 50% (cf. sec. 33(1) of the Austrian Income Tax Act). Interest, dividends and capital gains from stocks, bonds and real estate are in general subject to a flat rate of 25% (cf. secs. 30b(1) and 93(1) of the Austrian Income Tax Act). 2.6 The income tax base is defined as the sum total of the following categories: (i) income from agriculture and forestry; (ii) income from professional and other independent services; (iii) income from an active trade or business; (iv) employment income; (v) investment income; (vi) rent, lease payments and royalties; and (vii) other specified income (including certain annuities and capital gains on private property) (cf. sec. 2(3) of the Austrian Income Tax Act). Certain personal allowances exist for the taxpayer and family members (cf. sec. 33 of the Austrian Income Tax Act). 2.7 While income tax is levied by way of assessment, income tax on employment income is generally levied by way of withholding by the Austrian employer (cf. sec. 78(1) of the Austrian Income Tax Act). Such wage tax is a prepayment of the employee's final income tax and is credited against the employee's assessed income tax liability if the taxpayer files (voluntarily or in certain cases on an obligatory basis) an annual tax return. 2.8 Austria does not provide for a married couples tax splitting concept. Husband and wife are rather taxed separately on a stand-alone basis with their respective individual income. 2.9 Individuals are obliged to file their income tax returns electronically; paper-based filing is only exceptionally permissible. The income tax return must be filed by 30 April or, if electronic filing is made use of, by 30 June of the following year. Taxpayers represented by tax advisors benefit from longer deadlines. An extension of the filing date is possible in justified cases (cf. sec. 134 of the Austrian Federal Fiscal Procedures Act) Quarterly pre-payments of income tax are due on 15 February, 15 May, 15 August and 15 November. Such pre-payments are creditable against the final amount of income tax assessed. Any balance is payable within one month after receipt of the corporate income tax assessment notice (cf. sec. 45 of the Austrian Income Tax Act). 3. Corporate income tax 3.1 Corporations are subject to corporate income tax and thus taxed as separately taxable entities. Partnerships, in contrast thereto, are treated as transparent for tax purposes; the income of a partnership is attributed to its partners and subject to income tax or corporate income at the level of the partners. 3.2 Corporate income tax is levied at a rate of 25% (cf. sec. 22(1) of the Austrian Corporate Income Tax Act). 3
4 3.3 A corporation's tax basis is the profit as shown in its financial statements (cf. sec. 7(2) of the Austrian Corporate Income Tax Act; sec. 5(1) of the Austrian Income Tax Act). In addition, where mandatory tax provisions deviate from financial accounting rules, adjustments have to be made. As a general rule, expenses incurred in acquiring, securing and maintaining taxable income are tax-deductible. 3.4 The Austrian Corporate Income Tax Act provides for a broad participation exemption covering dividends and capital gains from subsidiaries (cf. sec. 10 of the Austrian Corporate Income Tax Act), as well as a group taxation regime for affiliated companies (cf. sec. 9 of the Austrian Corporate Income Tax Act). 4. Double taxation treaties 4.1 Austria's right to tax may be restricted by double taxation treaties. Austria has concluded 84 double taxation treaties, including one with the United States of America. 4.2 Austria generally follows the OECD Model Convention and the commentary thereto in respect to its treaty policy and interpretation. 4.3 Since under Austrian interpretational rules, the more specific provision takes precedence over the more general provision, double taxation treaties generally take priority over domestic laws. 4.4 Pursuant to an ordinance by the Austrian Minister of Finance, unilateral relief from double taxation is generally also possible if Austria has not concluded a double taxation treaty with a specific country. 5. FATCA 5.1 Austria has concluded an intergovernmental agreement with the United States of America aiming at facilitating the implementation of FATCA, which is based on the so-called Model Value added tax 6.1 Austria levies a value added tax at a rate of 20%; a reduced rate of 10% applies in particular to foodstuffs and beverages, agricultural products, books, plants, works of art, transportation of persons and residential rent (cf. sec. 10 of the Austrian Value Added Tax Act). 6.2 Both Austrian resident and non-resident entrepreneurs must register and account for value added tax if they deliver goods or render services within the sphere of their enterprise in Austria and against consideration (cf. sec. 1(1)(1) of the Austrian Value Added Tax Act). 6.3 There are a number of exemptions applicable to certain supplies (e.g., financial services and health services); an exemption also applies for entrepreneurs having their domicile or legal seat in Austria if their yearly turnover subject to value added tax does not exceed EUR 30,000 (cf. sec. 6 of the Austrian Value Added Tax Act). 4
5 7. Wealth tax 7.1 Austria does not levy a general wealth tax on all types of personal assets. 7.2 A special type of wealth tax only on Austrian real estate is currently being levied by the Austrian municipalities (cf. sec. 1 of the Austrian Land Tax Act [Grundsteuergesetz]). 8. Gift and inheritance tax 8.1 Austria currently does not levy a gift or inheritance tax. Such taxes were abolished in August There have been political discussions regarding a reintroduction. 8.2 Gifts and inheritances (as well as sales) of Austrian real estate trigger real estate transfer tax of normally 3.5% (cf. sec. 1(1)(1) of the Austrian Real Estate Transfer Tax Act [Grunderwerbsteuergesetz]). While the tax basis here is generally the fair market value, the three-fold standard tax value (Einheitswert) capped at 30% of the fair market value applies in the case of transfers to spouses, registered partners, companions having the same residence, parents, children, grandchildren, stepchildren, adopted children and children in law. 8.3 Gifts and inheritances of assets to Austrian private foundations are subject to a foundation entry tax at a rate of 2.5% or 25% (cf. sec. 1(1) of the Austrian Foundation Entry Tax Act [Stiftungseingangssteuergesetz]) 8.4 A special notification obligation exists for gifts of money, receivables, shares in corporations, participations in partnerships, businesses, movable tangible assets and intangibles (cf. sec. 121a of the Austrian Federal Fiscal Procedures Act). The notification obligation applies if the donor and/or the donee have a domicile, their habitual abode, their legal seat or their place of effective management in Austria. Both the donor and the donee are obliged to effect the gift notification within three months from the donation. The notification has to be done electronically. Intentional violation of the notification obligation may lead to the levying of fines of up to 10% of the fair market value of the assets transferred. Not all gifts are covered by the notification obligation: In case of gifts to certain related parties, a threshold of EUR 50,000 per year applies; in all other cases, a notification is obligatory if the value of gifts made exceeds an amount of EUR 15,000 during a period of five years. Furthermore, gratuitous transfers subject to Austrian foundation entry tax are exempt from the notification obligation. 9. Wealth management vehicles 9.1 Neither the Austrian Income Tax Act nor the Austrian Corporate Income Tax Act contains explicit provisions dealing with trusts. Given the fact that Austria is a civil law jurisdiction, this is hardly surprising. The trust concept is actually alien to Austrian civil and tax law. Very few court cases exist and not a lot of guidance has been given by the tax authorities concerning the Austrian tax consequences of setting up a trust, being a beneficiary of a trust and receiving benefits from a trust. Also, until recently not a lot of scholarly literature had been written on this topic. 5
6 9.2 Depending on their set-up, trusts can be seen for Austrian income tax purposes as either nontransparent (i.e., separate taxable entity) or as transparent (i.e., look-through). Broadly speaking, non-transparency is the case if neither the settlor nor the beneficiary has comprehensive instruction and supervision rights regarding the management of the trust assets; the settlor for example has no such rights (i) in the case of a testamentary trust, (ii) in the case of an inter vivos trust where he dies after setting up the trust and (iii) in the case of a discretionary trust where he has transferred the entire management to the trustees (who have full discretion) and where he has only determined the beneficiaries (cf. Austrian Supreme Administrative Court, 20 September 1988, 87/14/0167; EAS 2378; EAS 2804). Transparency would for example be the case with bare trusts, where the trustee acts on the instruction of the beneficiaries and has to transfer the assets to them upon request; the same would be true if the settlor had strong rights regarding the trust assets and these were transferred to the beneficiaries after his death (except, obviously, if the beneficiaries had no knowledge of the trust or their rights). 9.3 In practice, Austrian tax residents typically use an Austrian private foundation (Privatstiftung) for wealth management purposes. This is a legal entity without owners or shareholders, which is endowed with assets by the founder and which, by way of the use, management and investment of its assets, shall serve a legally valid purpose determined by the founder (cf. sec. 1(1) of the Austrian Act on Private Foundations [Privatstiftungsgesetz]). The private foundation is established by way of a unilateral declaration of intent by the founder and comes into legal existence by way of registration with the Austrian commercial register (cf. sec. 7(1) of the Austrian Act on Private Foundations). * * * 6
ADDITIONAL INFORMATION FOR INVESTORS IN AUSTRIA
1 ADDITIONAL INFORMATION FOR INVESTORS IN AUSTRIA COUNTRY SUPPLEMENT FOR BRANDES INVESTMENT FUNDS PLC This country supplement, dated 15 January 2018 contains information for Austrian investors regarding
More informationAustria Individual Taxation
Introduction Individuals are subject to national income tax. There are no local income taxes. After 1 August 2008, inheritance and gift tax is no longer levied. Social security contributions are also levied.
More informationGUIDANCE ON TAXATION OF BITCOINS AND OTHER CRYPTOCURRENCIES
GUIDANCE ON TAXATION OF BITCOINS AND OTHER CRYPTOCURRENCIES Recently, the Ministry of Finance published guidance on the Austrian income and value added tax aspects of investing in the crypto space. Given
More informationAUSTRIA TO IMPLEMENT (NON-PUBLIC) REGISTER OF BENEFICIAL OWNERS
AUSTRIA TO IMPLEMENT (NON-PUBLIC) REGISTER OF BENEFICIAL OWNERS On 7 June 2017, the draft bill of the Beneficial Owners Register Act (Wirtschaftliche Eigentümer Registergesetz) was approved by the Austrian
More informationTax Card KPMG in Macedonia. kpmg.com/mk
Tax Card 2016 KPMG in Macedonia kpmg.com/mk TAXATION OF CORPORATE PROFITS Corporate income tax (CIT) is due from profits realized by resident legal entities as well as by non-residents with a permanent
More information2018 TAX GUIDELINE. Poland.
2018 TAX GUIDELINE Poland poland@accace.com www.accace.com www.accace.pl Contents General information about Poland 4 Legal forms of business 5 General rules on purchasing real estate by foreigners 5 Legal
More information2018 TAX GUIDELINE. Slovakia.
2018 TAX GUIDELINE Slovakia slovakia@accace.com www.accace.com www.accace.sk Contents General information about Slovakia 3 Legal forms of business 4 General rules on purchasing of real estate 4 Share deal
More information(Incorporated as a joint stock company in the Republic of Austria under registered number FN m)
Prospectus Supplement No. 1 Erste Group Bank AG (Incorporated as a joint stock company in the Republic of Austria under registered number FN 33209 m) relating to the Structured Notes Programme This supplement
More informationSwitzerland. Investment basics
Switzerland Diego Weder Director Tel: +1 212 492 4432 diweder@deloitte.com Investment basics Currency Swiss Franc (CHF) Foreign exchange control restrictions are imposed on the import or export of capital.
More informationFOREWORD. Austria. Services provided by member firms include:
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 there
More informationInternational Tax Albania Highlights 2018
International Tax Albania Highlights 2018 Investment basics: Currency Albanian Lek (ALL) Foreign exchange control There are no foreign exchange controls; repatriation of funds may be made in any currency.
More informationThe Austrian Donations Tax Act 2008 for Foundations and Comparable Entities
Trusts & Trustees, Vol. 14, No. 8, October 2008 599 The Austrian Donations Tax Act 2008 for Foundations and Comparable Entities Christoph Kerres* and Florian Proell 1 Abstract This article considers the
More information2019 TAX GUIDELINE. Czech Republic.
2019 TAX GUIDELINE Czech Republic czechrepublic@accace.com www.accace.com www.accace.cz Contents General information about the Czech Republic... 3 Legal forms of business... 4 General rules on purchasing
More informationTaxation of individuals during a divorce can be potentially complicated by one or both of the parties being classified as non UK resident.
Cross border divorce 1 August 2017 Meg Saksida considers the tax aspects of cross border expatriate divorce What is the issue? Taxation of individuals during a divorce can be potentially complicated by
More informationGermany Taxable income. Introduction. 1. Income Tax Taxable persons. This chapter is based on information available up to 11 March 2010.
This chapter is based on information available up to 11 March 2010. Introduction Individuals are subject to income tax, which is increased by a solidarity surcharge. Individuals carrying on a trade or
More informationInternational Tax Germany Highlights 2018
International Tax Germany Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No restrictions are imposed on the import or export of capital; however, a declaration must be
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 informationThe most important legislative changes in Slovakia as of 2018 ebook
The most important legislative changes in Slovakia as of 2018 ebook INTRODUCTION Are you wondering about the most significant changes in the Slovak legislation with the arrival of 2018? Our experts have
More informationInternational Estate and Inheritance Tax Guide 2012
International Estate and Inheritance Tax Guide 2012 Preface The International Estate and Inheritance Tax Guide 2012 (IEITG) is published by Ernst & Young s Personal Tax Services network, which comprises
More informationCountry Author: Taylor Wessing
The Legal 500 & The In-House Lawyer Comparative Legal Guide Germany: Private Client This country-specific Q&A provides an overview to private client law in Germany. It will cover taxes, succession laws,
More informationTax Card With effect from 1 January 2016 Lithuania. KPMG Baltics, UAB. kpmg.com/lt
Tax Card 2016 With effect from 1 January 2016 Lithuania KPMG Baltics, UAB kpmg.com/lt CORPORATE INCOME TAX Taxable profit of Lithuanian and foreign corporate taxpayers is subject to a standard (flat) rate
More informationBULGARIAN TAX GUIDE 2017
GLOBAL CONSULT EUROPE LTD. Sofia 1504, Bulgaria 23A San Stefano str. Tel : +359 889 85 00 87 info@companyinbg.com www.companyinbg.com BULGARIAN TAX GUIDE 2017 I. CORPORATE INCOME TAX (CIT) Resident companies
More informationEXPATRIATE TAX GUIDE. Taxation of income from employment in the EU & EEA
EXPATRIATE TAX GUIDE Taxation of income from employment in the EU & EEA Poland 2016 CONTENTS* 2 Austria 4 Belgium 6 Bulgaria 8 Croatia 10 Cyprus 12 Czech Republic 14 Denmark 16 Estonia 18 Finland 20 France
More informationLex Mundi European Union: Accession States Tax Guide. SLOVENIA Vidovic & Partners
Lex Mundi European Union: Accession States Tax Guide SLOVENIA Vidovic & Partners CONTACT INFORMATION: Natasa Vidovic Vidovic & Partners Tel: 386.1.500.73.20 - Fax: 386.1.500.73.22 E-mail: vp@vidovic-op.si
More informationFOREWORD. Slovak Republic
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 there
More informationTAX PROFILE, ESTONIA. (published in BNAI's Global Tax Guide) KEY FACTS INTRODUCTION RECENT DEVELOPMENTS. Kaido Loor and Elvira Tulvik
TAX PROFILE, ESTONIA (published in BNAI's Global Tax Guide) Kaido Loor and Elvira Tulvik Estonia Pärnu mnt 15, 10141 Tallinn phone +372 6 400 900, estonia@sorainen.com Latvia Kr. Valdemāra iela 21, LV-1010
More informationALBANIA TAX CARD 2017
ALBANIA TAX CARD 2017 TAX CARD 2017 ALBANIA Table of Contents 1. Individuals 1.1 Personal Income Tax 1.1.1 Tax Rates 1.1.2 Taxable Income 1.1.3 Exempt Income 1.1.4 Deductible Expenses 1.2 Social Security
More informationOverview of Italy s Tax Provisions on Trusts
Volume 73, Number 3 January 20, 2014 Overview of Italy s Tax Provisions on Trusts by Rossi Q. Rossi Reprinted from Tax Notes Int l, January 20, 2014, p. 243 Overview of Italy s Tax Provisions on Trusts
More informationTax Residency of Individuals: Switzerland
Tax Residency of Individuals: Switzerland STEP Israel Annual Conference Tel Aviv, June 20, 2017 Dr. Ruth Bloch-Riemer Bär & Karrer AG, Zürich Agenda Swiss Domestic Law - Types of Tax Liability - Tax Residency
More informationInternational Tax Belgium Highlights 2018
International Tax Belgium Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements Belgian GAAP. IFRS is mandatory for consolidated
More informationIreland Country Profile
Ireland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Ireland EU Member State Yes Double Tax Treaties With: Albania Armenia Australia
More informationFOREWORD. Montenegro. Services provided by member firms include:
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 informationInternational Tax Croatia Highlights 2018
International Tax Croatia Highlights 2018 Investment basics: Currency Croatian Kuna (HRK) Foreign exchange control The Foreign Exchange Act regulates domestic and foreign currency transactions. Legal entities,
More informationishares Physical Metals plc
SUPPLEMENT DATED 17 OCTOBER 2016 TO THE BASE PROSPECTUS DATED 11 DECEMBER 2015 RELATING TO THE SECURED PRECIOUS METAL LINKED SECURITIES PROGRAMME ishares Physical Metals plc (Incorporated as a public company
More informationAustria Country Profile
Austria Country Profile EU Tax Centre March 2014 Key tax factors for efficient cross-border business and investment involving Austria EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationInternational Tax Luxembourg Highlights 2018
International Tax Luxembourg Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements Luxembourg GAAP/IFRS. Financial statements must
More informationFOREWORD. Algeria. Services provided by member firms include:
2015 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?
More informationInternational Tax Slovenia Highlights 2018
International Tax Slovenia Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Bank accounts may be held and repatriation payments made in any currency. Accounting principles/financial
More informationSPECIAL TAX REGIMES IN PORTUGAL: THE NON-HABITUAL TAX RESIDENT REGIME
SPECIAL TAX REGIMES IN PORTUGAL: THE NON-HABITUAL TAX RESIDENT REGIME Introduction In recent years, Portugal introduced several measures that aim to promote foreign investment and the relocation of individuals
More informationEuropean Union: Accession States Tax Guide. LITHUANIA Lawin
A. General information European Union: Accession States Tax Guide LITHUANIA Lawin CONTACT INFORMATION Gintaras Balcius Lawin Jogailos 9/1 Vilnius, LT-01116 Lithuania 370.5.268.18.88 gintaras.balcius@lawin.lt
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 informationTax Guide For Foreign Investors In U.S. Residential Real Estate
A T T O R N E Y S A T L A W Tax Guide For Foreign Investors In U.S. Residential Real Estate 2018 Edition In this guide I. Introduction 2 II. The U.S. Tax System 3 A. U.S. Persons 3 1. Basic Rules 3 2.
More informationDoing Business in Austria
Doing Business in Austria www.bakertillyinternational.com Contents 1 Fact Sheet 2 2 Business Entities and Accounting 4 2.1 Companies 4 2.2 Partnerships 5 2.3 Sole Proprietorship 6 2.4 Branches 6 2.5 Private
More informationSerbian Tax Card 2018
Serbian Tax Card 2018 KPMG d.o.o. Beograd kpmg.com/rs CORPORATE INCOME TAX A resident is a legal entity which is incorporated or has a place of effective management and control on the territory of Serbia.
More informationHungary. Structure and development of tax revenues. Hungary. Table HU.1: Revenue (% of GDP)
Structure and development of tax revenues Table HU.1: Revenue (% of GDP) 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 I. Indirect taxes 16.2 15.6 15.1 16.0 15.8 16.6 17.7 17.5 18.8 18.7 VAT 8.8 8.3
More informationTax Card KPMG in Bulgaria. kpmg.com/bg
Tax Card 2017 KPMG in Bulgaria kpmg.com/bg CORPORATE TAX Corporate income tax (CIT) is due on the accounting profit after adjustments for tax purposes. The applicable tax rate for the year 2017 is 10%.
More informationSerbia Country Profile
Serbia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Serbia EU Member State Double Tax Treaties With: Albania Austria Azerbaijan Belarus
More informationLuxembourg income tax 2018 Guide for individuals
Luxembourg income tax 2018 Guide for individuals www.pwc.lu 2 Table of Contents Basic principles Employment income Directors fees Dividend and interest income 1 2 3 4 5 Capital gains p4 p8 p9 p9 p10 Real
More information2017 Transfer Pricing Overview Poland
2017 Transfer Pricing Overview Poland poland@accace.com www.accace.com www.accace.pl Contents Applicable Legislation 3 Transactions Subject to Transfer Pricing Documentation 4 Scope of Transfer Pricing
More informationNew York State Bar Association International Section
New York State Bar Association International Section 2014 Annual Seasonal Meeting Vienna, Austria Program 23: Trusts in Civil Law Jurisdictions Friday, October 17 th, 2014 3:45 pm - 5:00 pm COUNTRY REPORT
More informationMongolia Tax Profile. Produced in conjunction with the KPMG Asia Pacific Tax Centre. Updated: June 2015
Mongolia Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation 6 3 Indirect
More informationRBC Wealth Management Services
RBC Wealth Management Services The Navigator C HARLES W. C ULLEN III CFP(Canada and U.S.),CIM Associate Portfolio Manager & Wealth Advisor 902-424-1092 charles.cullen@rbc.com D AYNA P ARK Associate 902-421-0244
More informationMontenegro a place to invest in
Montenegro a place to invest in Easy business start up Hub for regional business Strategic geographical position National treatment of foreigners Dynamic economyc growth and development Favourable tax
More informationInternational Tax Turkey Highlights 2018
International Tax Turkey Highlights 2018 Investment basics: Currency Turkish Lira (TRY) Foreign exchange control The TRY is fully convertible, at least from the Turkish side, to the extent Turkey is recognized
More informationFOREWORD. Finland. Services provided by member firms include:
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 there
More informationSTEP Bahamas. 11 th October The tax treatment of trusts in Continental Europe: Belgium, France, Germany, Italy, the Netherlands and Switzerland
STEP Bahamas 11 th October 2005 The tax treatment of trusts in Continental Europe: Belgium, France, Germany, Italy, the Netherlands and Switzerland Jean-Marc Tirard and Maryse Naudin Tirard, Naudin Paris
More informationTaxation of individuals
Taxation of individuals Luxembourg 2016 kpmg.lu Tax year The tax year corresponds to the calendar year. Tax rates Progressive tax rates ranging from 0% to 42.8% apply to taxable income not exceeding 150,000
More informationOVERVIEW OF THE SWISS TAX SYSTEM
OVERVIEW OF THE SWISS TAX SYSTEM 10.1 Taxation of Corporate Taxpayers... 109 10.2 Tax Charge Rate in International Comparison... 112 10.3 Taxation of Individual Taxpayers... 113 10.4 Withholding Tax...
More informationInternational Estate and Inheritance Tax Guide 2013
International Estate and Inheritance Tax Guide 2013 Preface The International Estate and Inheritance Tax Guide 2013 (IEITG) is published by Ernst & Young s Personal Tax Services network, which comprises
More informationBRIEF STATISTICS 2009
BRIEF STATISTICS 2009 Finnish Tax Administration The Tax Administration is organized under the jurisdiction of the Ministry of Finance. The Tax Administration collects about two-thirds of the taxes and
More informationMontenegro Country Profile
Montenegro Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Montenegro EU Member State (EU candidate) Double Tax Treaties With: Albania
More informationTax Card 2018 Effective from 1 January 2018 The Republic of Estonia
Tax Card 2018 Effective from 1 January 2018 The Republic of Estonia KPMG Baltics OÜ kpmg.com/ee CORPORATE INCOME TAX In Estonia, corporate income tax is not levied when profit is earned but when it is
More informationNewsletter Nr. 201 (EN) Tax Residency in Germany, China, Hong Kong and Thailand
Newsletter Nr. 201 (EN) Tax Residency in Germany, China, Hong Kong and Thailand January 2019 A ll ri ght s res erv ed Lo r enz & Partners 201 9 Although Lorenz & Partners always pays great attention on
More informationTAX CONSEQUENCES FOR U.S. CITIZENS AND OTHER U.S. PERSONS LIVING IN CANADA
TAX CONSEQUENCES FOR U.S. CITIZENS AND OTHER U.S. PERSONS LIVING IN CANADA Over the past few years, there has been increased media attention in Canada with respect to the U.S. income tax filing requirements
More informationFINLAND TAX DESKBOOK
LEX MUNDI INTERNATONAL TAX DESKBOOK EDITORS: John R. Barsanti, Jr. and Robert Lewis Jackson Armtrong Teasdale LLP One Metropolitan Square St Louis, Missouri 63102 FINLAND TAX DESKBOOK PREPARED BY Gunnar
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 informationTECHNICAL EXPLANATION OF THE UNITED STATES-JAPAN INCOME TAX CONVENTION GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 JANUARY 1973 TABLE OF ARTICLES
TECHNICAL EXPLANATION OF THE UNITED STATES-JAPAN INCOME TAX CONVENTION GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 JANUARY 1973 It is the practice of the Treasury Department to prepare for the use of the
More information2018 Transfer Pricing Overview Romania
2018 Transfer Pricing Overview Romania romania.office@accace.com www.accace.com www.accace.ro Contents Introduction 3 Applicable legislation 4 Arm s length principle 5 Related parties 6 Documentation 7
More informationThe Netherlands. Arcagna Attorneys at Law & Tax Advisers Arnold van der Smeede
The Netherlands Arcagna Attorneys at Law & Tax Advisers Arnold van der Smeede 1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Introduction The laws of succession are included in Book 4 of The Netherlands Civil
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 information1. Mandatory Transfer Pricing Documentation starting from 2016!
In the following we give you an overview of the latest and most important tax innovations: 1. Mandatory Transfer Pricing Documentation starting from 2016!... 1 2. EU Interest Limitation Rule coming soon!...
More informationSlovenia Country Profile
Slovenia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Slovenia EU Member State Double Tax Treaties With: Albania Armenia Austria
More informationInternational Tax Ukraine Highlights 2018
International Tax Ukraine Highlights 2018 Investment basics: Currency Ukrainian Hryvnia (UAH) Foreign exchange control Only local currency generally may be used in business transactions between residents.
More information2018 Transfer Pricing Overview Poland
2018 Transfer Pricing Overview Poland poland@accace.com www.accace.com www.accace.pl Contents Introduction 3 Applicable Legislation 4 Transactions Subject to Transfer Pricing Documentation 5 Scope of Transfer
More informationTax Planning for US Bound Clients
Tax Planning for US Bound Clients International Wealth Planners Geneva, 15 June 2011 Michael Parets Withers LLP, Zurich Office +41 44 488 8803 direct michael.parets@withersworldwide.com US-Bound Clients
More informationTaxation (Bright-line Test for Residential Land) Bill
Taxation (Bright-line Test for Residential Land) Bill Commentary on the Bill Hon Todd McClay Minister of Revenue First published in August 2015 by Policy and Strategy, Inland Revenue, P O Box 2198, Wellington
More informationSetting up business in... Serbia
Setting up business in... Serbia General Aspects Republic of Serbia is located in South East Europe at the intersection of Pan European Corridors Nr. 10 and Nr. 7 linking Europe and Asia and is bordered
More informationInternational Tax Chile Highlights 2018
International Tax Chile Highlights 2018 Investment basics: Currency Chilean Peso (CLP) Foreign exchange control Entities and individuals are free to enter into any kind of foreign exchange transactions,
More informationTAXATION OF EXPATRIATES WORKING IN THE SLOVAK REPUBLIC OUR OFFICES:
TAXATION OF EXPATRIATES WORKING IN THE SLOVAK REPUBLIC OUR OFFICES: guide2007.p65 1 Leitner + Leitner No reliance should be placed on nor should decisions be taken on the basis of the contents of this
More informationFOREWORD. Czech Republic
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 there
More informationFOREWORD. Slovak Republic
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 informationAnalysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September
Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September 18, 2007 Effective date: In the P.R.C., from January
More informationInternational Tax Indonesia Highlights 2018
International Tax Indonesia Highlights 2018 Investment basics: Currency Indonesian Rupiah (IDR) Foreign exchange control The rupiah is freely convertible. However, approval of Bank Indonesia (the central
More informationMulti-jurisdictional estate planning and administration
Multi-jurisdictional estate planning and administration Fiduciary Institute of Southern Africa August 2017 Oliver Phipps, Partner Introduction a small world South African fiduciary practitioners regularly
More informationDoing Business in the Czech Republic
This document describes some of the key commercial and taxation factors that are relevant on setting up a business in the Czech Republic. Prepared by Peterka and Partners 2 Doing Business in the Czech
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 informationCA. Divakar Vijayasarathy
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 Death leads to movement
More informationSETTING UP BUSINESS IN SERBIA
www.antea-int.com SETTING UP BUSINESS IN SERBIA 1 General Aspects Republic of Serbia is located in South East Europe at the intersection of Pan European Corridors Nr. 10 and Nr. 7 linking Europe and Asia
More informationBelgium - Income Tax. Tax returns and compliance. Residents. Non-residents. 1 April 2016 Taxation of international executives
Belgium - Income Tax 1 April 2016 Taxation of international executives Tax returns and compliance When are tax returns due? That is, what is the tax return due date? 30 June for residents and, in principle,
More informationALTER EGO TRUSTS AND JOINT PARTNER TRUSTS
ALTER EGO TRUSTS AND JOINT PARTNER TRUSTS This issue of the Legal Business Report provides current information to the clients of Alpert Law Firm on estate planning, including alter ego and joint partner
More informationTransfer Pricing in Central and South Eastern Europe
Transfer Pricing in Central and South Eastern Europe Country Reports Albania Austria Bulgaria Croatia Czech Republic Hungary Poland Romania Serbia Slovakia Slovenia Foreword OECD Base Erosion and Profit
More informationTaxation in Ireland A Summary*
Taxation in Ireland A Summary* William Fry 2 Grand Canal Square Dublin 2 Ireland www.williamfry.com William Fry 2015 www.williamfry.com Copyright William Fry 2015. All Rights Reserved In Association with
More informationInternational Tax Slovakia Highlights 2019
International Tax Updated January 2019 Investment basics: Currency Euro (EUR) Foreign exchange control No restrictions are imposed on the import or export of capital, and repatriation payments may be made
More informationWEALTH PLANNING CONSIDERATIONS IN MEXICO. A Guide for Clients of Morgan Stanley International Wealth Management
WEALTH PLANNING CONSIDERATIONS IN MEXICO A Guide for Clients of Morgan Stanley International Wealth Management A. INTRODUCTION Morgan Stanley International Wealth Management has had the opportunity to
More informationFOREWORD. Isle of Man
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 there
More informationSwiss tax implications of cross-border employment and social security pitfalls
Swiss tax implications of cross-border employment and social security pitfalls Severine Vogel Attorney-at-Law, LL.M., Certified Tax Expert Staiger Attorneys at Law Ltd Contents I. Tax Law Domestic Swiss
More informationCOMPARISON OF EUROPEAN HOLDING COMPANY REGIMES
COMPARISON OF EUROPEAN HOLDING COMPANY REGIMES This analysis provides an indicative guide only and advice from appropriate country specialists should always be sought. Particular attention should be given
More informationEXPAT TAX HANDBOOK. Non-Citizens and U.S. Tax Residency. Tax Year Ephraim Moss, Esq Ext 101
EXPAT TAX HANDBOOK Non-Citizens and U.S. Tax Residency Tax Year 2018 Ephraim Moss, Esq. 718-887-9933 Ext 101 emoss@expattaxprofessionals.com Joshua Ashman, CPA 718-887-9933 Ext 102 jashman@expattaxprofessionals.com
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 informationOverview of the Canadian income tax system
The Navigator INVESTMENT, TAX AND LIFESTYLE PERSPECTIVES FROM RBC WEALTH MANAGEMENT SERVICES Cullen Wealth Management RBC Dominion Securities Charles W. Cullen III, CFP, CIM Vice-President, Portfolio Manager
More information