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June 2020: International Tax Planning Review

June 2020: International Tax Planning Review

Russian-Cypriot negotiations to amend double tax treaty On 25 June 2020 Russia and Cyprus started negotiations on amendments to the Agreement for the avoidance of double taxation dated 5 December 1998 (as amended in 2010) existing between the countries. Russia’s position is that the payment of dividends from Russia to Cyprus should be taxed in

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The Netherlands has introduced beneficial ownership register

The Netherlands has introduced beneficial ownership register

On 23 June, 2020 the Parliament of the Netherlands has adopted a Law №35179 by which the centralized beneficial ownership register is established as required by EU Directive ЕС 2015/849. Some data from the register will be available to the public. The duty to execute and to file beneficial ownership registers with the Trade Register

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UK

Controlled Foreign Companies rules in the United Kingdom

Controlled Foreign Companies (CFC) rules are applicable to entities resident in foreign jurisdictions and controlled by UK residents. In some cases, CFC rules are also applicable to permanent establishments of UK resident companies abroad. Controlling persons As provided by subsection 3 of Section 371AA of Taxation (International and Other Provisions Act) 2010 any person (natural

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European Commission

May 2020: International Tax Planning Review

Aggressive tax planning: the European Commission gives recommendations to six Member States The European Commission has issued recommendations to the EU Member States, six of which have been advised to enhance countering ‘aggressive’ tax planning.     The aggressive tax planning holds an intermediate position between allowable tax planning and tax evasion (and cannot be equated

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Several EU Member States have been warned of non-compliance with 5th Anti-Money Laundering Directive

The report on infringements of different EU acts committed by some Member States has been published on 14 May 2020 in the website of European Commission. Such infringements include non-compliance of national anti-money laundering and combating terrorist financing (AML/TF) legislation of several Member States with the requirements of the EU Directive 2018/843, which is applicable

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United Kingdom: tax residency and domicile of individuals

United Kingdom: tax residency and domicile of individuals

One of the main features of taxation of private individuals in the UK is the specific approach to determination of tax relationship of an individual with the state. The regime of taxation of incomes of individuals who are resident in the UK for tax purposes depends on whether such individuals are domiciled in the UK

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Seychelles has adopted centralized beneficial ownership register

Seychelles has adopted centralized beneficial ownership register

On 5 March 2020 President and National Assembly of Seychelles have officially enacted Beneficial Ownership Act 2020 (the Act) which establishes centralized beneficial ownership registers with confidential regime of data storage for the first time. Firstly, it is necessary to mention that the requirements under abovementioned Act are applicable both to legal persons incorporated in

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Panama

Cayman Islands, Panama and Seychelles added to the EU “blacklist”

18 February 2020 the European Commission has published an information about the regular update of the “blacklist” of non-cooperative jurisdictions for tax purposes. This time it was decided to list 4 new jurisdictions. In February 2020 Cayman Islands, Palau, Panama and Seychelles have been added to the “blacklist”. As a result, the current version of

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EU warns several Member States of need to reform their anti-money laundering legislation

EU warns several Member States of need to reform their anti-money laundering legislation

On 12 February 2020 the information that European Commission has sent formal written notices to some Member States warning on non-compliance of their national anti-money laundering and terrorist financing (AML/FT) legislation with current European standards established by EU Directive 2018/843 and other acts has appeared. According to European Commission, the legislation of the following states does

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Cyprus: imposition of annual trade license fees in Limassol municipality

Cyprus: imposition of annual trade license fees in Limassol municipality

In December 2019 the Municipality of Limassol has published an information of imposition of annual trade license fees on legal entities in this region of Cyprus on its official website. The abovementioned decision was made 26 September 2019 in accordance with Articles 104 and 105 of the Municipalities Law 111/1985. The requirement to pay annual

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