• BRUSH UP: DUTCH STATUTORY AUDIT AND CONSOLIDATION REQUIREMENTS

    Too often directors as well as ultimate beneficial owners of a Dutch private limited liability company (“Besloten Vennootschap or B.V.”) or a public limited liability company (“Naamloze Vennootschap or N.V.”) that act as a top or intermediary holding company of an international group do not realize that the company should... Read more »
  • THE END OF DENMARK AS A HOLDING COMPANY JURISDICTION

    New anti-abuse rules introduced retroactively from 3 October 2012 On 14 December 2012 the Danish Parliament passed the draft Bill (L 10) introducing new antiabuse rules responding to unintended consequences of the earlier rules, i.e. respond to the possibilities to avoid Danish taxes and/or foreign taxes by using Danish companies. These rules will apply retroactively from 3 October... Read more »
  • NETHERLANDS RULES REGARDING RESTRICTION OF INTEREST DEDUCTION AMENDED

    Thin capitalization rules abolished On 20 November 2012, the Second Chamber of Parliament approved the Bill including the abolition of the thin-capitalisation rules with respect to the deduction of interest expenses for Dutch corporation tax. This takes effect for taxable years commencing on or after 1 January 2013. New rule regarding the restriction of interest deduction These... Read more »
  • BRUSH UP: THE LUXEMBOURG PRIVATE WEALTH MANAGEMENT COMPANY

    Societe de Patrimoine Familiale or SPF By law dated 11 May 2007, the Luxembourg government introduced the “Societe de Patrimoine Familiale or SPF” to replace the 1929 Holding Company regime which was terminated on 1 January 2007 after it was found by the European Commission to be in violation of state aid rules for providing... Read more »
  • INTRODUCTION OF FOUNDATIONS IN GUERNSEY

    From January 9, 2013 On 7 January 2013 the Foundations (Guernsey) Law 2012, approved by the Privy Council on 12 December 2012, which legislates for the introduction of the foundations form in Guernsey, was registered in the Royal Court. From January 9, 2013 the Guernsey Registry has to begun to accept applications for the formation of... Read more »
  • EC ACTION PLAN TO STRENGTHEN THE FIGHT AGAINST TAX FRAUD AMD TAX EVASION

    Communication COM (2012) 351 of 27 June 2012 In our newsletter of July last year, we informed you that on 27 June 2012 the European Commission issued Communication COM (2012) 351 on concrete ways to reinforce the fight against tax fraud and tax evasion including in relation to third countries.  Moreover, we informed you that it... Read more »
  • THE END OF THE SWISS LUMP SUM TAXATION REGIME?

    Swiss lump sum taxation regime The Swiss lump sum taxation regime is granted at the federal level and in all cantons (with the exception of a number of cantons as mentioned below) of Switzerland and offers high net worth individuals with foreign nationality, who do not derive income from employment in Switzerland, the possibility to be... Read more »
  • CYPRUS REMOVED FROM RUSSIAN BLACKLIST

    Effective 1 January 2013 Effective 1 January 2013, Cyprus will no longer be on the Russian Ministry of Finance’s list of offshore zones, also known as the “blacklist”. The removal is the result of the ratification in 2012 of the 2010 Protocol to the Russia-Cyprus tax treaty that applies generally from 1 January 2013 (except for... Read more »
  • NEW DOUBLE TAX TREATY BETWEEN UKRAINE AND CYPRUS

    Signed on 8 November 2012 Following several years of negotiations, a new double tax treaty between the Ukraine and Cyprus was signed on 8 November 2012 during an official visit of Ukraine’s President Viktor Yanukovych to Cyprus. To replace the USSR – Cyprus double tax treaty of 1982 Once ratified by both countries, the new... Read more »
  • STATUS OF THE NEW TAX ARRANGEMENT BETWEEN THE NETHERLANDS AND CURACAO

    In our newsletter of December 2011 we informed you that, on 12 December 2011, the Dutch Ministry of Finance published the headlines of a new Tax Arrangement for the Kingdom of the Netherlands (Belastingregeling voor het Koninkrijk or BRK), which provides for the avoidance of double taxation on income and capital between the Netherlands and Curacao. This new... Read more »
  • BRITISH VIRGIN ISLANDS: NEW RECORD KEEPING AND RETENTION REQUIREMENTS

    On 12 November 2012 changes have been introduced to the record keeping and record retention obligations of all companies and limited partnerships in the British Virgin Islands with the enactment of the Mutual Legal Assistance (Tax Matters) (Amendment) Act 2012, and the Partnership (Amendment) Act 2012. The amending Acts were published in the Official Gazette on 26 November... Read more »
  • NEW DOUBLE TAX TREATY BETWEEN UKRAINE AND CYPRUS

    Signed on 8 November 2012 Following several years of negotiations, a new double tax treaty between the Ukraine and Cyprus was signed on 8 November 2012 during an official visit of Ukraine’s President Viktor Yanukovych to Cyprus. To replace the USSR – Cyprus double tax treaty of 1982 Once ratified... Read more »
  • STATUS OF THE NEW TAX ARRANGEMENT BETWEEN THE NETHERLANDS AND CURACAO

    In our newsletter of December 2011 we informed you that, on 12 December 2011, the Dutch Ministry of Finance published the headlines of a new Tax Arrangement for the Kingdom of the Netherlands (Belastingregeling voor het Koninkrijk or BRK), which provides for the avoidance of double taxation on income and... Read more »
  • BRITISH VIRGIN ISLANDS: NEW RECORD KEEPING AND RETENTION REQUIREMENTS

    On 12 November 2012 changes have been introduced to the record keeping and record retention obligations of all companies and limited partnerships in the British Virgin Islands with the enactment of the Mutual Legal Assistance (Tax Matters) (Amendment) Act 2012, and the Partnership (Amendment) Act 2012. The amending Acts were... Read more »
  • COMPARISON OF EUROPEAN HOLDING COMPANY LOCATIONS AS AT 1 SEPTEMBER 2012

    Click here to view our most recent "Comparison of holding company locations".... Read more »
  • NETHERLANDS VAT RATE WILL INCREASE TO 21% AS PER OCTOBER 1, 2012

    On 11 July 2012 the Dutch Senate adopted the increase of the standard VAT rate from 19% to 21% with effect from 1 October 2012. The reduced rate for certain goods and services will remain 6%. Decisive factor for applying the higher VAT rate The moment that the pertinent goods... Read more »
  • CURACAO TAX REFORM 2011-2014

    As we have informed you in our newsletter of December 2010, as a consequence of a Constitutional Reform, the Netherlands Antilles, which had existed since 1954 as an autonomous Caribbean country within the Kingdom of the Netherlands, was dissolved on 10 October 2010. At the same time Curacao became a... Read more »
  • SIMPLIFICATION AND FLEXIBILIZATION OF DUTCH CORPORATE LAW CONCERNING BV’S

    On 12 June 2012 the Senate (Eerste Kamer) of the Dutch Parliament finally adopted the bill for the simplification and flexibilization of the rules on Dutch private limited liability companies (“Wet vereenvoudiging en Flexibilisering B.V.-recht”) and the bill relating to the implementation of these rules, the Implementation Act (“Invoeringswet”), hereinafter... Read more »
  • SPANISH HIGH COURTS DECIDES ARM’S LENGTH VALUATION

    On October 13, 2011, the Spanish High Court of Appeal (“Audiencia Nacional”) issued an interesting decision on arm’s length valuation of participative loans. For Spanish legal purposes, a participative loan falls within a hybrid category –similar to shareholders' subordinated loans- with the following main features: Remuneration (interest) must be variable... Read more »
  • SPANISH HIGH COURT RECHARACTERIZES PARTICIPATIVE LOAN AS EQUITY

    The decision of funding a company through debt or equity has significant income tax consequences. In many cases, taxpayers elect debt since when the investment is paid back to the lender, deductible interest may result to the entity. However, frequent disputes arise between taxpayers and tax authorities as to whether... Read more »
  • POLAND: CHANGE TO POLISH-CYPRIOT TAX TREATY

    Changes to the Polish-Cypriot tax treaty have been negotiated by the Polish Ministry of Finance. Details of the changes have not been officially released, however, the Ministry of Finance has indicated informally that the key changes relate to: the removal of the ‘tax sparing’ clause which made it possible to... Read more »
  • DECLARATION OF NO OBJECTION FOR INCORPORATION DUTCH COMPANIES ABOLISHED

    On 9 June 2010 the Upper House of the Dutch parliament approved the “Bill amending, among other things, Book 2 of the Dutch Civil Code and the Companies (Documentation) Act”. Effective from 1 July 2011 Consequently, as from 1 July 2011 a declaration of no objection for the incorporation and... Read more »
  • BELGIAN BILL ON VARIOUS LEGAL AMENDMENTS ON CORPORATE TAX ADOPTED

    On 31 March 2011, Bill No. 53/1208/001 concerning various legal amendments was adopted by the Belgian Upper House. Measures apply retroactively from 1 January 2011 The tax measures mainly relate to adjustments following infringement procedures started by the European Commission. The measures, which apply retroactively from 1 January 2011, include... Read more »
  • SWITZERLAND IS STRENGTHENING ITS POSITION AS HOLDING COMPANY LOCATION

    Switzerland is continuously strengthening its position as a location to base an intermediate holding company by way of tax reforms. Corporate Tax Reform I The aim of the so-called “Corporate Tax Reform I”, which was implemented in the late nineties, was to boost Switzerland as a competitive international holding location... Read more »
  • BRUSH UP: VAT ON LEASING OF MALTESE REGISTERED YACHTS MAY BE REDUCED TO 5.4%

    This brush-up will elaborate about the Maltese VAT treatment of yacht leasing arrangements which may reduce the VAT rate on the lease and possible acquisition of a yacht to 5.4% of the original price of the yachts. Guidelines of 24 November 2005 On 24 November 2005, the Maltese VAT Department... Read more »
  • NEW STATUTORY RESIDENCE TEST PLUS CHANGES TO THE TAXATION REGIME FOR NON-DOMS

    New consultation documents issued: 1. Proposals for a new statutory residence test; 2. Further changes to the taxation regime for non-doms After many years of increasing uncertainty, the UK seems set to now introduce a detailed statutory residence test. Anyone spending time in the UK who wishes to be regarded as... Read more »
  • ITALY REMOVES CYPRUS AND MALTA FROM BLACKLISTS

    Italy has three blacklists of countries considered to have tax systems which favour the avoidance of taxation. By way of a Ministerial Decree issued on 27 July, 2010, Italy removed Cyprus and Malta from its blacklists. The Decree applies as from 4 August 2010, the date it was published in... Read more »
  • SOUTH AFRICA INTRODUCES DIVIDENDS TAX FROM 1 APRIL 2012

    On 23 February 2011, South Africa’s Minister of Finance presented the Budget for 2011- 2012, which contains a broad range of proposed changes to the corporate and personal income tax rules, social contributions and indirect taxes. According to the Budget, the corporate tax rate will remain unchanged at 28% and... Read more »
  • ITPS OPENS OFFICES IN BELIZE

    We are proud to inform you that we can now offer you services from our new Belize office, please find below the contact details: ITPS (Belize) Ltd. Belize Marina Towers Suite 303, Newtown Barracks, Belize City Belize T: +357 22556 802 E: m.ioannides@itps-group.com.cy Contact: Mrs. Maria Ioannides... Read more »
  • ITPS OPENS OFFICES IN MALTA AND HONG KONG

    We are delighted to let you know that, after the opening of our office in Belize in May of this year, we opened this month also offices in Hong Kong and Malta. Please find below the contact details of our new offices: ITPS (Hong Kong) Ltd. 6th Floor, ING Tower... Read more »

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