#Taxation Archives - Page 14 of 14 - Law firm Finance Business Service: offshore registration, tax planning, legal services

Switzerland, US Agree FATCA

Published: Sergey Panov | 03.03.2016 | news

Switzerland and the United States agreed on a new Foreign Account Tax Compliance Act (FATCA), with the exception of accounts belonging to lawyers and notaries. In accordance with the provision of the agreement, an account maintained for specific purposes by lawyers and notaries to their customers (ie accounts that are for certain activities) will be excluded from the scope of the new law. The financial institution account management will not be required to identify interested customers by providing written confirmation of a lawyer or notary that the accounts fall under the scope of the exemption clause. According to the Swiss Federal Council, this will ensure that professional confidentiality of lawyers and notaries will be maintained under Swiss law. Swiss Bankers Association will amend the relevant processes documentation to allow banks implement new products. Negotiations on the introduction of the new agreement are underway. In contrast to the current transaction, the new agreement will provide for the automatic exchange of information between the tax authorities. Author: Olena Kutova senior lawyer of the Finance Business...

Luxembourg announces corporate tax reduction

Published: Sergey Panov | 02.03.2016 |

The Luxembourg government has announced a package of tax measures that will be introduced next year including the reduction of the corporate tax and changes to the personal income tax. The government plans a gradual corporate tax rate reduction by three percent. Starting with the two percent cut to 19 percent by January 1, 2017. And since January 2018, the rate will drop to 18 percent. In addition, a lower rate of 15 percent will be available for the "young, innovative companies ", annual taxable income that does not exceed EUR 25,000 per year. Nevertheless, the company's ability to carry losses forward to offset against future income will be limited in 2017. Existing law allows unlimited number of losses of previous years. Starting next year, the accumulated losses can be carried forward only for 10 years and use to compensate for a maximum of 80 percent of profits. The government also intends to revocation of provisional 0.5% percent crisis tax in 2017 and make income tax system more "fair" by reducing tax rates. However, the tax on high incomes which exceed EUR 150000 would be 41% and revenues more than EUR 200,000 - 42 percent. Author: Sergey Panovmanaging...

Double tax treaty between Cyprus and Switzerland

Published: Sergey Panov | 01.03.2016 |

The first Cyprus-Switzerland double tax treaty (DTT), signed in 2014, entered into force in October 2015 with its provisions taking effect as from January 1, 2016. Under the treaty there is no withholding tax (WHT) on interest and royalties. There is also no WHT on dividends in those cases where the beneficial owner of the dividends is: a company (other than a partnership), the capital of which is wholly or partly divided into shares, holding directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of at least one year (the time period criterion may be satisfied post the date of the dividend payment), or a pension fund or similar institution recognized as such for tax purposes, or the government, a political subdivision, local authority, or the central bank of one of the two Contracting States. Per the treaty, a 15% WHT on dividends applies in all other cases. Irrespective of this, per the provisions of Cyprus’ domestic tax legislation, Cyprus does not apply WHT on dividend payments out of Cyprus at all times. Author: Sergey Panovmanaging partner Finance Business...

Financial Institutions Tax (FIT) in Poland

Published: Sergey Panov | 29.02.2016 |

The Polish Parliament adopted the bill introducing a new tax on financial institutions (called also a bank levy). The bill was passed for signature of the President. It entered into force from February 1, 2016. Generally, the tax applies to banks, credit unions, lending institutions, as well as insurance/reinsurance companies. The new tax applies also to Polish branches of foreign banks (credit institutions) and foreign insurance/reinsurance companies. The funds are out of scope. According to the new law, the tax base is defined as the surplus of total assets disclosed in the financial institution’s accounting books exceeding certain amount calculated at the end of each month. In the case of banks and credit unions, as a rule, the tax base will be decreased by the amount of their equity. Author: Sergey Panovmanaging partner Finance Business...

Dividends paid to non-residents of Ukraine

Published: Sergey Panov | 09.10.2013 | news

In this article, we propose to consider the main issues related to the payment of dividends to non-residents of Ukraine, that is, the individuals / juridical persons who are representatives of other states. First of all, it should be noted that Ukrainian law provides the right of foreign investors to ensure they receive all the profits obtained in our country legally. This immediately indicates that the resident of Ukraine, being the actual issuer of corporate rights, who carries out the payment of dividends to non-residents, is subject to the general legislation on taxation. That means that regardless of the fact to whom the payment of dividends is made, the issuer is obliged to pay an advance fee of 25% without reducing the amount of dividends. International agreements related to the elimination or reduction of double taxation of income does not apply to this payment. Now let's discuss in more details the payment of dividends to legal entities which are non-residents of Ukraine. First of all, we emphasize that when paying dividends to non-resident, who is in fact a legal entity, but has no such status, the issuer of corporate rights is obliged to withdraw 15% withholding...

Optimization of tax payments: schemes, methods, rules

Published: Sergey Panov | 06.09.2011 |

The history of taxation has a long old root, as an existing of any country. As long, the country will exist, as long the citizen will pay taxes. The owners of small and big business see a direct threat in taxes for them capital. The state has it's own interest in this question as a sole proprietorships. As we see, it's not so easy to create a fair system of taxation. In such way in tax culture, more often is used term "tax planning". The main aim of tax planning is to get financial result when taxation payments will be minimized. The development of tax planning in a right way take great part, because it give an opportunity to use niceties of tax legislation in a whole size. Because of this lost during tax payment minimized. The main directions of external tax planning: replacement of the subject of taxes, that is, changing the company form to one that will be more suitable for the implementation of this regime; new activities (meaning a form of activity, which will be subject to a more simplified) replacement tax jurisdiction (registration of the company in the region, where preferential tax treatment) The internal planning is carried out by optimizing accounting. The...

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