• Articles

Article Directory


What has Happened in the World of International Business Structuring since Lockdown on March 23rd

The IBSA’s global reach has been an unintended beneficiary of lockdown with a shift from our ‘physical’ meetings to our 30 minute weekly online discussion group meetings, our ‘Tuesday Club’. [...]
Date: 01 Jul 2020
Jurisdiction: Worldwide

Should Cryptocurrency be part of my Divorce Settlement

Cryptocurrency, though used by only a small part of the general population, is increasingly subject to litigation as its use becomes more widespread and it starts to figure in disputes, both commercial and personal. An increasing number of divorce cases feature cryptocurrency[...]
Date: 10 Jun 2020

UAE Cabinet issues the positive list for Foreign Direct Investment Law

There has been a significant development for foreign investors that are interested in investing in, or have already invested in, companies in the UAE. Cabinet Resolution No.16 of 2020 sets out the 'positive list' of sectors and economic activities in which 100% foreign direct[...]
Date: 13 May 2020

Economic Substance Regulations - An Update and Next Steps

On 30 April 2019, the UAE Cabinet issued the Cabinet of Ministers Resolution No.31 of 2019 (concerning economic substance regulations in the UAE, “the Regulations”), requiring all in-scope UAE entities (“Relevant Entities”) that carry on certain activities (“Relevant[...]
Date: 14 Apr 2020
Jurisdiction: United Arab Emirates
Subjects: Economic Substance

Changes of Tax Residency - Summary and Options

Concept:- Determining residential status is core tenet of ascertaining tax implications under the Income Tax Act, 1961 (the Act). In India, as in many other countries, the charge of income tax and scope of taxable income depends entirely on residential status. There are two[...]
Date: 02 Apr 2020
Jurisdiction: United Arab Emirates

DAC6 - Who, What, Why, When, Where and How

The HMRC description on DAC6 - “The regulations will require taxpayers and their advisers to report details of certain types of cross-border arrangement to HMRC. An arrangement will be reportable if it contains certain characteristics, known as hallmarks. Being reportable will[...]
Date: 09 Mar 2020

International Aspects of US Tax Law - February 2020

I hope 2020 is off to a good start for all readers of this Article. I wanted to give a very broad overview of some aspects of US international tax system as at early 2020. I have picked the following six broad topics to discuss:[...]
Date: 10 Feb 2020
Jurisdiction: United States of America
Subjects: TaxIncome Tax

DAC 6: UK implementation of the new EU tax disclosure rules

DAC 6 imposes mandatory reporting of cross-border arrangements affecting at least one EU member state where the arrangements fall within one of a number of “hallmarks”. The use of broad categories designed to encompass particular characteristics viewed as indicative of[...]
Date: 07 Aug 2019
Jurisdiction: United Kingdom

Corporate Residence - How to keep management and control where you want it

A company that is not incorporated in the UK may be treated as UK tax resident if it is centrally managed and controlled here. Much careful tax planning can be undone if this point is not well understood and continually monitored. [...]
Date: 05 Aug 2019
Jurisdiction: United Kingdom

OECD Assessment of Low-Tax Jurisdictions Updated - UAE is close to compliance

The July 23rd 2019 report of the OECD Forum (Organisation for Economic Co-operation and Development) on Harmful Tax Practices (HTP) has concluded that 11 of the 12 countries on its list of low-tax jurisdictions are compliant with its standards for ‘substantial activity’[...]
Date: 29 Jul 2019
Jurisdiction: United Arab Emirates