Kozusko Harris Duncan | USA | 2 Sep 2021
For various reasons, some US citizens and Green Card holders are considering living abroad. How tax professionals and trust officers worldwide advise these individuals depends on their objectives. Does the individual want to live in another country for a limited number of years or to change domicile and resettle permanently? Will the individual be working abroad or living off savings and......
Elias Neocleous & Co LLC | Cyprus | 18 Jan 2019
The Income Tax Law was recently amended to provide an exemption of up to 50% for income derived from the production of films, series and other relevant audiovisual media. In addition, small enterprises may claim an annual deduction of 20% of the cost of cinematographic infrastructure and technological equipment, provided that it has been used in Cyprus for at least five years.
Carey Olsen | Bermuda | 17 Jan 2019
Many offshore financial centres, including Bermuda, laboured to meet the EU Council's end-of-year deadline to impose economic substance requirements on entities that carry on 'geographically mobile' business activities. For jurisdictions subject to the deadline, failure to introduce substance laws may result in being placed on the EU Council's list of non-cooperative jurisdictions for tax......
Cliffe Dekker Hofmeyr | South Africa | 11 Jan 2019
The South African Revenue Service recently published the fourth issue of Interpretation Note 64, which seeks to provide guidance on the application and interpretation of Section 10(1)(e) of the Income Tax Act. With the rising prevalence of complex developments, security estates, shopping centres, wellness compounds and high-rise flats in South Africa, body corporates, homeowners' associations......
Elias Neocleous & Co LLC | Cyprus | 14 Dec 2018
The Cyprus Tax Department recently published for consultation draft legislation to implement the EU Tax Dispute Resolution Mechanisms Directive. The draft legislation comprises an amending law, which adds two new articles to the Income Tax Law 2002 and regulations to be issued under the second of those articles. The new law is intended to take effect from 1 July 2019.
Lewis Silkin | United Kingdom | 12 Dec 2018
The government's plan to make termination payments in excess of £30,000 subject to employer national insurance contributions has been delayed for a second time and will now take effect from April 2020. Initially this change was expected to be introduced from April 2018; however, the Autumn 2017 Budget announced that it would take effect from April 2019. The further delay is welcome news for......
BDO LLP | India | 16 Nov 2018
Alongside new guidance from the Central Board of Taxes regarding securities transaction tax, potential legislative amendments may be introduced regarding interest income on rupee denominated bonds. Further, the Chennai Tax Tribunal recently considered whether a tax officer had been correct in invoking Section 56(2)(viib) of the Income Tax Act, citing an unrealistic premium, in a case where a......
Cliffe Dekker Hofmeyr | South Africa | 16 Nov 2018
The South African Revenue Service recently published Binding Private Ruling 310, which deals with the tax treatment of customer loyalty programmes. The applicant was a local company supplying goods and services in the course of trade, which had – in order to enhance its business – proposed to implement a customer loyalty programme through which participating customers could benefit.
Cliffe Dekker Hofmeyr | South Africa | 9 Nov 2018
The South African courts have held, on a number of occasions, that taxpayers are entitled to deduct damages or compensation paid to third parties. However, this principle does not apply in all cases. A recent High Court decision has made clear that before a taxpayer calculatedly breaches an agreement, it should carefully consider the incidence of tax.
BDO LLP | India | 2 Nov 2018
A number of new circulars, notifications and press releases have been issued in recent months. Among other things, they introduce new valuation rules for the conversion or treatment of inventory as capital assets, grant taxpayers immunity from the penalty for under-reporting income and clarify the deductions available for free trade zone undertakings.