Tax Planning For Temporary Non Residents In 2013/2014


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This finding suggests that tax avoidance in EU firms may have, on average, decreased over time. We use cookies to help provide and enhance our service and tailor content and ads. By continuing you agree to the use of cookies. Download PDF Download. Author links open overlay panel Martin Thomsen Christoph Watrin. Under a Creative Commons license.

Abstract In recent years, the international tax policy debate has focused on the tax avoidance strategies applied by multinational firms. JEL classification H Investors and entrepreneurs have to take some risks while doing their jobs, and these risks can be influenced by taxes. There is an absence of insurance markets.

Federal Budget: New Legislation for Personal Income Tax Measures | Boughton Law

However, even if there were more solid conditions in the sector of investment, there would still be a small percentage of entrepreneurs taking the risk. It is possible for some capital gains taxes to boost risk taking. If the investor decides to split up investments to both alternatives, even if the risky one ends up being a loss, he can through the income tax in combination with full loss deductibility gain most of his lost money back, incentivizing investors to take the risk.

Australia collects capital gains tax only upon realized capital gains, except for certain provisions relating to deferred- interest debt such as zero-coupon bonds. The tax is not separate in its own right, but forms part of the income-tax system. The proceeds of an asset sold less its "cost base" the original cost plus additions for cost price increases over time are the capital gain. Discounts and other concessions apply to certain taxpayers in varying circumstances.

Capital gains tax is collected from assets anywhere in the world, not only in Australia. The amount left after applying the discount is added to the assessable income of the taxpayer for that financial year. For individuals, the most significant exemption is the principal family home when not used for business purposes such as rental income or home-based business activity.

5 Key Tax Planning Concepts for Non-Residents

The sale of personal residential property is normally exempt from capital gains tax, except for gains realized during any period in which the property was unused as a personal residence for example, while leased to other tenants or portions attributable to business use. Capital gains or losses as a general rule can be disregarded for CGT purposes when assets were acquired before 20 September pre-CGT.

Tax packages for all years

Under the participation exemption, capital gains realised by a Belgian resident company on shares in a Belgian or foreign company are fully exempt from corporate income tax, provided that the dividends on the shares qualify for the participation exemption. For purposes of the participation exemption for capital gains the minimum participation test is not required.

Unrealised capital gains on shares that are recognised in the financial statements which recognition is not mandatory are taxable. But a roll-over relief is granted if, and as long as, the gain is booked in a separate reserve account on the balance sheet and is not used for distribution or allocation of any kind. As a counterpart to the new exemption of realised capital gains, capital losses on shares, both realised and unrealised, are no longer tax deductible. However, the loss incurred in connection with the liquidation of a subsidiary company remains deductible up to the amount of the paid-up share capital.

Other capital gains are taxed at the ordinary rate. If the total amount of sales is used for the purchase of depreciable fixed assets within 3 years, the taxation of the capital gains will be spread over the depreciable period of these assets. Capital gain taxes are only paid on realized gains. Derivatives futures and options follow the same rules for tax purposes as company stocks. Also, non-residents have no tax on capital gains.

There is no capital gains tax on equity instruments traded on the BSE. Some exceptions apply, such as selling one's primary residence which may be exempt from taxation. As of the budget, interest can no longer be claimed as a capital gain. The formula is the same for capital losses and these can be carried forward indefinitely to offset future years' capital gains; capital losses not used in the current year can also be carried back to the previous three tax years to offset capital gains tax paid in those years.

Capital gains earned on income in a Registered Retirement Savings Plan are not taxed at the time the gain is realized i. These gains are then taxed at the individual's full marginal rate. Capital gains earned on income in a TFSA are not taxed at the time the gain is realized. Any money withdrawn from a TFSA, including capital gains, are also not taxed. The applicable tax rate for capital gains in China depends upon the nature of the taxpayer i.

It should however be noted that, unlike common law tax systems, Chinese income tax legislation does not provide a distinction between income and capital. What is commonly referred to by taxpayers and practitioners as capital gain tax is actually within the income tax framework, rather than a separate regime.

Current Australian IncomeTax Rates - Resident and Non-Resident

In practice, where a resident of a treaty partner alienates assets situated in China as part of its ordinary course of business the gains so derived will likely be assessed as if it is a capital gain, rather than business profit. This is somewhat contradictory with the basic principles of double taxation treaty. The circular addresses the withholding tax treatment of dividends and interest received by QFIIs from PRC resident companies, however, circular 47 is silent on the treatment of capital gains derived by QFIIs on the trading of A-shares.

It is generally accepted that Circular 47 is intentionally silent on capital gains and a possible indication that SAT is considering, but still undecided on, whether to grant tax exemption or other concessionary treatment to capital gains derived by QFIIs.

This uncertainty has caused significant problems for those investment managers investing in A-Shares. Guo Shui Han No. With respect to Circular itself, there are views that it is not consistent with the Enterprise Income Tax Law as well as double taxation treaties signed by the Chinese government. The validity of the Circular is controversial, especially in light of recent developments in the international arena, such as the TPG case in Australia and Vodafone case in India.

As determined by the Cyprus Capital Gains Tax Law, Capital gains tax in Cyprus arising from the sale or disposition of immovable property in Cyprus or the disposal of shares of companies which own immovable property in Cyprus and not listed in a recognised stock exchange. These gains are not added to other income but are taxed separately. Payment of immovable property tax is paid by both individuals and companies on property owned in Cyprus. Capital gains tax does not apply to profits from the sale of overseas real estate by non-residents, offshore entities, or residents who were not resident when they purchased the asset.

Gains accruing from disposal of immovable property held outside Cyprus and shares in companies, the property whereof consists of immovable property held outside Cyprus, will be exempted from capital gains tax. Individuals may, subject to certain conditions, may claim certain deductions from the applicable taxable gain. Capital gains in the Czech Republic are taxed as income for companies and individuals. For an individual, gain from the sale of a primary private dwelling, held for at least 2 years, is tax exempt.

Or, when not used as a main residence, if held for more than 5 years. Interest paid on loans is deductible, although in case the net capital income is negative, only approx.

Year-End Planning With A Qualified Charitable Distribution (QCD) From An IRA

Resident entities are taxed on worldwide income. Nonresidents are subject to tax only on Ecuador-source income. Companies engaged in the exploration or exploitation of hydrocarbon also are subject to the standard corporate tax rate. Resident individuals are taxed on their worldwide income; nonresidents are taxed only on Ecuadorian-source income. There was no capital gains tax.

This proposal came to life on 29 May Egypt exempt bonus shares from a new 10 percent capital gains tax on profits made on the stock market as the country's Finance Minister Hany Dimian said on 30 May , and distributions of bonus shares will be exempt from the taxes, and the new tax will not be retroactive. There is no separate capital gains tax in Estonia. Resident natural persons that have investment account can realise capital gains on some classes of assets tax free until withdrawal of funds from the investment account.

For resident legal persons includes partnerships no tax is payable for realising capital gain or receiving any other type of income , but only on payment of dividends, payments from capital exceeding contributions to capital and payments not related to business. However, capital gains from the sale of residential homes is tax-free after two years of residence, with certain limitations. For residents, there are now two options for treating capital gains shares, bonds, interests, etc.. The second option is to opt for the former treatment whereby gains are taxed at The following year, 6.

If shares are held in a special account called a PEA , the gain is subject only to "social contributions" The gain realized on the sale of a principal residence is not taxable. A gain realized on the sale of other real estate held at least 30 years, however, is not taxable, although this will become subject to There is a sliding scale for non principal residence property owned for between 22 and 30 years.

Non-residents are generally taxable on capital gains realized on French real estate and on some French financial instruments, subject to any applicable double tax treaty. Social security taxes, however, are not usually payable by non-residents. A French tax representative will be mandatory if you are non-resident and you sell a property for an amount over In January , Germany introduced a very strict capital gains tax called Abgeltungsteuer in German for shares, funds, certificates, bank interest rates etc.

Capital gains tax only applies to financial instruments shares, bonds etc. Instruments bought before this date are exempt from capital gains tax assuming that they have been held for at least 12 months , even if they are sold in or later, barring a change of law. Certificates are treated specially, and only qualify for tax exemption if they have been bought before 15 March Real estate continues to be exempt from capital gains tax if it has been held for more than ten years.

Deductions of expenses such as custodian fees, travel to annual shareholder meetings, legal and tax advice, interest paid on loans to buy shares, etc. In general Hong Kong has no capital gains tax. However, employees who receive shares or options as part of their remuneration are taxed at the normal Hong Kong income tax rate on the value of the shares or options at the end of any vesting period less any amount that the individual paid for the grant. If part of the vesting period is spent outside Hong Kong then the tax payable in Hong Kong is pro-rated based on the proportion of time spent working in Hong Kong.

Therefore, it is possible depending on the country of origin for employees moving to Hong Kong to pay full income tax on vested shares in both their country of origin and in Hong Kong. Similarly, an employee leaving Hong Kong can incur double taxation on the unrealized capital gains of their vested shares.

The Hong Kong taxation of capital gains on employee shares or options that are subject to a vesting period, is at odds with the treatment of unrestricted shares or options which are free of capital gains tax. For those who do trading professionally buying and selling securities frequently to obtain an income for living as "traders", this will be considered income subject to personal income tax rates. This includes: selling stocks, bonds, mutual funds shares and also interests from bank deposits. Since January , Hungarian citizens can open special "long-term" accounts.


  1. REPORT on tax rulings and other measures similar in nature or effect.
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  3. Canada Revenue Agency Annual Report to Parliament 2013-2014.
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Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014
Tax Planning For Temporary Non Residents In 2013/2014 Tax Planning For Temporary Non Residents In 2013/2014

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