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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

Investment Funds in United Arab Emirates (UAE)

The United Arab Emirates (UAE) was formed in 1971 and originally consisted of Abu Dhabi, Ajman, Dubai, Fujairah, Sharjah, and Umm Al Quwain. This was a historic year for them because it was also in this year that these territories were liberated from British rule. The following[...]
Date: 01 Jul 2019
Jurisdiction: United Arab Emirates
Subjects: Investment Funds

BVI Economic Substance Law

The British Virgin Islands (BVI) has passed legislation requiring certain legal entities which carry on ‘relevant activities’ to demonstrate that they have adequate economic substance in the BVI.[...]
Date: 03 Jun 2019
Jurisdiction: British Virgin Islands
Subjects: Economic Substance

There is no such thing as a No-Deal Brexit

The Brexit discussion meeting at Close Brothers Asset Management on Thursday, 30th May was a fascinating insight into the legal, political and economic consequences of Brexit. Despite my having chosen a date for this discussion some months ago, thinking that 30th May would be[...]
Date: 03 Jun 2019
Subjects: Brexit

VAT issues that may affect your business

VAT updates on Brexit, customs, Making Tax Digital and more: This briefing contains timely information on VAT issues that may affect your business.[...]
Date: 03 Jun 2019
Jurisdiction: United Kingdom
Subjects: VATBrexit