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Tax Flash International

Two BEPS measures introduced into the Australian Parliament

By Robert Gordon, Pointon Partners on February 8th, 2019 [...]

Corporate inversion – a new green path: The transfer of shares in an Israeli company to a foreign company that is resident in a treaty country

By Artzi, Hiba, Elmekiesse, Cohen – Tax Solutions Ltd. on February 13th, 2019 [...]

Post-implementation review of the Tax Transparency Code in Australia

By Yiallourides & Partners Ltd on February 4nd, 2019 [...]

Malta’s labour marked has increased resulting in a very low rate of unemployment

Malta announces its 2019 Budget whereby the country has recorded an growth economic growth leaving surplus of 1% in the country’s GDP. Malta’s labour marked has increased resulting in a very low rate of unemployment... [...]

OVDP Ended Sept. 28 – So Now What?

We originally posted on March 13, 2018 IRS to End OVDP Sept. 28 – Last Chance for Taxpayers With Undisclosed Foreign Assets! where we discussed that the Internal Revenue Service announced in IR-2018-52 that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018... [...]

PNG’s Internal Revenue Commission (IRC) hosted a Meet and Greet session

On October 12, 2018, PNG’s Internal Revenue Commission (IRC) hosted a Meet and Greet session for certain large tax payers, at Revenue Haus in Port Moresby, and Shishya Business Services was a special invitee. The important attached to this initiative is clearly visible, as less than 3 weeks ago, we saw the Deputy Prime Minister & Treasurer, officially open the Large Taxpayer Office (LTO)... [...]

Proceeds from Export of Goods Must Be Brought Into To Turkey And A Minimum Of 80% Of The Said Proceeds Are Required To Be Sold To The Banks

Communiqué No. 48 regarding the Decree No. 32 on the Protection of the Value of the Turkish Currency is published in the Official Gazette on September 4th, 2018 and entered into force on the same date. The changes will be in effect for a period of 6 months as from the date of its entry into force... [...]

Accelerated Reduction of Company Tax Rates now Law

The previously legislated tax cuts for small business included a reduction to eligible entity’s rate to 27.5% and a progressive ramp up of the Turnover threshold, peaking in the current FY19 year at $50 million. After a stabilising period, the rate was then legislated to fall from 27.5% to 25% during the FY25 through FY27 years... [...]

Anti-Money Laundering & Countering Financing Of Terrorism (AML/CFT)

You may have already been asked for increased proof of identity and in some cases, information regarding your tax residency by your bank or lawyer. From 1 October 2018 all New Zealand Accountants need to comply with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009... [...]

Malta goes Blockchain

Malta introduces the enactment of three pieces of legislation; namely: The Malta Digital Innovation Act, The Innovative Technology Arrangement and Services Act, and The Virtual Financial Assets Act... [...]

New startup visa introduced in Shanghai

Shanghai’s Public Security Bureau introduced, in May 2018, a new ‘’Private Residence Permit (Entrepreneurship)’’, most commonly known as ‘’Business Startup visa’’ (创业签证), which enables foreign entrepreneurs to live in China while launching their innovative business in Shanghai... [...]

China proposes new measures for foreign investors’ strategic investments in listed companies

The Chinese Ministry of Commerce (‘’MOC’’) released on 30 July 2018 a draft on the amended Administrative Measures for Strategic Investment by Foreign Investors in Listed Companies (the ‘’Draft’’), which aims at further opening the Chinese market to foreign investors. The Draft is set to revise the existing laws and regulations (the ‘’Existing Measures’’), in effect since 30 January 2006... [...]

China Individual Income Tax Reform

The Chinese government has recently released the draft amendments to the Individual Income Tax (“IIT”) Law to the public for consultation. The proposed amendments comprise broad changes to the IIT system and the salient proposed changes are as follows... [...]

US Expats with non US corporations

US Expats with non US corporations, hold your hats…..The Tax Cuts and Jobs Act (TCJA) of 2017 imposed a one time “deemed repatriation tax” or ‘transition tax’ of 15.5% on untaxed foreign earnings or business profits accumulated overseas from 1986- 12/31/17 held in cash or cash-equivalents and 8% for profits held in non-cash form, whether or not the funds had been repatriated by deeming these earnings to be repatriated. .. [...]

150 Offshore Banks Are Turning Over Your Names To The IRS and the OVDP Program Ends on Sept. 28 – What Are You Waiting For?

The Internal Revenue Service announced in IR-2018-52 on March 13, 2018 that it will close the OVDP program on Sept. 28, 2018. “Taxpayers Have Had Several Years to Come into Compliance with US Tax Laws under This Program,” Said Acting IRS Commissioner David Kautter. “All along, We Have Been Clear That We Would Close the Program at the Appropriate Time, and We Have Reached That Point... [...]

AGM 2018 Los Angeles

AITC held its AGM in Los Angeles between the 31st August and 2nd September 2018 hosted by our USA member Law Offices of John A. Strain. AITC would like to take this opportunity to thank its hosts for this year’s AGM and for their sterling job in organising our meeting and including this year’s new initiatives to the Agenda... [...]

Property acquisition opportunities in Mauritius: a must visit destination

Mauritius, ideally located in the Indian Ocean, has a mild, tropical climate year-round and is praised for its idyllic landscape and luxurious island living style. It is now considered to be one of the tropical destinations that offers opportunities to foreign investors to buy real property under different schemes. One of the schemes concerned with the acquisition of property is the Property Development Scheme (PDS)... [...]


This article highlights the changes introduced to tax remittance process by Internal Revenue Commission (IRC) of PNG, from 1 June 2018, Unacceptable payment methods, Personal Cheque and Company Cheque... [...]


Africa is the world’s second largest and second most-populous continent with a population more than 1.25 billion. Today, Africa comprises of 54 sovereign countries, most of which have borders that were drawn during the era of European colonialism... [...]

AITC Welcomes the New Panama Member

The President and the Board of AITC welcome Mr. Alessandro Cavallera of N&C Capital as a new member within the association and wish a rewarding mutual cooperation... [...]

Managing the Foreign remittance process in Papua New Guinea

In the past few years, we have seen PNG facing acute shortage of foreign currency and businesses are hard hit. In this month’s write up, we have focused on Foreign Remittance process in PNG and ways to get around. For easy understanding we have used a Q&A approach... [...]

India: Tax & Professional updates For May 2018

RBI came up with the latest changes on ECB on the 27th of April 2018, which has been incorporated in the Master Directions. In light of the requests received from corporates for further relaxation of norms in the ECB regulations. Central Board of Direct Tax notifies the Protocol amending the Double Taxation Avoidance Agreement (DTAA) between India and Kuwait... [...]

2018 Australian Federal Budget – A Business Perspective

The 2018 Federal Budget was in Tax and fiscal terms was a generally a lacklustre affair. Herein is a business perspective synopsis. Company Tax Rates: No changes excepting as previously announced... [...]

The Offshore Voluntary Disclosure Program and Cryptocurrency

Do you think the IRS’s recent announcement that it is ending its Offshore Voluntary Disclosure Program (OVDP) and Streamlined program just as its enforcement of cryptocurrency compliance increases is a coincidence? The IRS issued a John Doe Summons to Coinbase (winning its dispute over Coinbase to obtain its virtual currency records and requiring Coinbase to disclose identifying information... [...]

US Expatriates Living Abroad – What You Should Know About the New Tax Law – Part II

US Expatriates Living Abroad – What You Should Know About the New Tax Law – Part II The Tax Cuts and Jobs Act 2017 (TCJA) changed many things, including reporting and taxing requirements for US taxpayers living abroad. While the plan was marketed as a much needed tax simplification for Americans... [...]

Mauritius: 50 years of Independence this year

Mauritius having attained its independence on 12 March 1968, has celebrated it’s 50 years of Independence this year. The Golden Jubilee of Independence marks a key milestone in the history of Mauritius and is a reminder of how far the country has come in terms of its economic development evolving from a mono-crop economy to a diversified economy... [...]

Creatrust Securitisation Platform

Promoters or Issuers use securitisation vehicles as an alternative to traditional bank funding, to transfer risk or deconsolidate risk off their balance sheet. Securitisation is an operation by which investors buy securities in order to obtain the proceeds from the investments made by... [...]

US Expatriates Living Abroad – What You Should Know About the New Tax Law – Part I

The Tax Cuts and Jobs Act 2017 (TCJA) changed many things, including reporting and taxing requirements for US taxpayers living abroad. While the plan was marketed as a much needed tax simplification for Americans; the TCJA did not provide much relief, let alone simplification, for U.S. taxpayers living abroad (Expats)... [...]

Hong Kong continues to expand its tax treaty network – New double taxation agreement with India

Hong Kong has recently signed a comprehensive double taxation agreement (CDTA) with India. This brings the number of CDTAs Hong Kong has concluded with other jurisdictions to 39. It is expected that Hong Kong will sign more and more CDTAs with other jurisdictions and in particular... [...]

India: Professional updates for April 2018

CBIC clarified that LUT shall be deemed to be accepted on Generation of ARN, No documents required to be physically submitted to Jurisdictional Office. RBI has decided to defer implementation of Indian Accounting Standard (Ind AS) by one year for the banks. Scheduled... [...]

Why it is important to reconcile your tax balance regularly

In this month’s write up, we will highlight the importance of reconciling your taxes with the revenue authority in PNG (IRC). What is Tax reconciliation? Tax reconciliation is a process which involves confirming tax compliance... [...]

$1 Billion in Refunds Still Unclaimed from 2014 Returns

Under Internal Revenue Code Section 6511(a)Period of Limitation on Filing Claim.— a claim for refund or credit must be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed... [...]

New IP Box Regime in Luxembourg – 5,2% effective tax rate – BEPS compliant.

Luxembourg is known for its favorable intellectual property regime. Its legislation is also one of the main reasons why foreign investors are highly interested in opening intellectual property holding companies in the Grand Duchy... [...]

India: Tax & Professional updates For March 2018

RBI had discontinued the Letter of Undertaking (LOU) & Letter of Comfort (LOC) for trade credit for import into India with immediate effect from. RBI has notified the Separate limit of Interest Rate Futures (IRFs) for Foreign Portfolio Investors (FPIs). Currently, the FPI limit... [...]

A comparison of Cyprus and BVI corporate structures in the light of recent global tax reforms.

The recent revelations in the Panama and Paradise Papers illustrated the need for companies to make a shift towards more responsible fiscal behaviour and tax responsibilities. International guidelines such as the OECD guidelines and the 4th EU AML Directive clarify that evasive fiscal practices... [...]

Interest on Home Equity Loans Often Still Deductible Under New Law

WASHINGTON – The Internal Revenue Service today advised taxpayers that in many cases they can continue to deduct interest paid on home equity loans. Responding to many questions received from taxpayers and tax professionals... [...]

Austrian premium for research and development has been increased to 14% as of January 1, 2018

In Austria, companies that carry out research and development are financially supported by the state. They may claim a research premium for certain research and development expenses. This research premium is valid regardless of the legal form of the company... [...]

1st Taxpayer Victory in a “Willful” FBAR Penalty Case!

On September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer friendly opinion regarding the “willfulness” standard in FBAR penalty matters. In Bedrosian v. United States, Case No... [...]

Hong Kong uses massive fiscal surplus to spur innovation and alleviate taxes

Hong Kong recently announced record-breaking fiscal surplus of 138 billion HKD from the 2017-18 fiscal year. This is mostly thanks to high revenue from profits tax, land sales, stamp duties and salaries tax. Last year was indeed exceptional for the Asia’s world city, as its economy grew by 3.8%... [...]

New chairperson for the National Council of Tax Advisors

On the weekend of 12th-14th of January 2018, the Fifth National Convention of Tax Advisors was held in Warsaw. A new chairperson for the National Council of Tax Advisors was appointed during a vote – Adam Marianski, assistant professor in the Department of Tax Law of the University of Lodz... [...]

Are you getting your GST Refunds on time?

This write up highlights the GST Refund process followed in Papua New Guinea (PNG) and is useful for all business, who are eligible for refund claim. We have adopted a question-answer approach, to make this more informative. What is GST refund and does my business qualify... [...]

Initial Coin Offering – BlockChain – Bitcoin Funds

The SLP can be used to setup up a Bitcoin Fund as an Unregulated Alternative Investment Fund. An ICO (Initial Coin Offering) is a fundraising method, operating via the issue of digital assets exchangeable against cryptocurrencies during the start-up phase of a project... [...]

Foreign LPs Investing in Australia

There has been a heartening development in the long running uncertainly about the access to treaty benefits for partners in foreign limited partnerships investing into Australia, at least where the foreign LP is actually a partnership at general law (e.g. Cayman LP), and not incorporated (e.g. UK LLP)... [...]

IRS to Begin Revoking US Passports of Delinquent Taxpayers in 2018!

Starting this month, the IRS will start implementing new procedures required under a 2015 law to crack down on individuals with “seriously delinquent tax debts.” The IRS issued Notice 2018-1 on January 16, 2018, which provides guidance for implementation of the new IRC 7345... [...]

Two-tiered Profits Tax Rates Regime in Hong Kong

A two-tiered profits tax rates regime was proposed by the Hong Kong Government during the last quarter of 2017 and the relevant Inland Revenue (Amendment) (No.7) Bill 2017 (the “Bill”) was gazetted and introduced to the Legislative Council early this year. Subject to the enactment... [...]

Cyprus VAT on Land – Updates by the Tax Department

In November 2017, the Cyprus parliament voted an important amendment to the Cyprus VAT Legislation, which amends the main VAT Law N.95(I)/2000 concerning taxation of building land, in order to align it with the provisions of EU VAT Directive 2006/112/EC. The amendment has entered into force on 2 January 2018... [...]

IRS Urges Travelers Requiring Passports to Pay Their Back Taxes or Enter into Payment Agreements; People Owing $51,000 or More Covered

On January 16, 2018 the IRS further warned that Travelers Requiring Passports to Pay Their Back Taxes or Enter into Payment Agreements; People Owing $51,000 or More Covered. This month, the IRS will begin implementation of new procedures affecting individuals with “seriously delinquent... [...]

Turkey: 5% of income tax and corporate tax rate deduction would be applied as of 1 January 2018 under certain conditions.

The General Communiqué No: 301 on Income Tax was published in the Official Gazette dated December 23, 2017 and numbered 30279 made explanations on the application of tax deduction to compliant taxpayers... [...]

Papua New Guinea Key Compliance Dates for 2018

Shishya, a consulting firm specialising in servicing Asia Pacific markets, has kindly provided the Papua New Guinea Key Compliance Dates for 2018 in an easy to follow table shown below. For more information, kindly... [...]

Argentina enacts integral Tax Reform introducing significant changes in decades

Argentina enacted an integral tax reform through Law 27.430 (published on the Official Gazette on December 29th 2017), which became effective as from January 1st 2018. The Law includes changes that would affect the taxation of both residents and non-residents. It introduces relevant changes to... [...]

Register of Beneficial Owners in Malta

On the 26th December by virtue of Legal Notice 374 of 2017 as of the 1st January 2018 the Registrar of the Registry of Companies shall compile a register of the beneficial owners of each company that is registered. The register shall be known as the Register of Beneficial Owners... [...]

Minimum salaries for foreign workers rise 33 percent in Romania

Romanian authorities have increased minimum salary levels for foreign employees by 33 percent as the country prepares for a new system in which employees, rather than employers, will be responsible for social security costs. Effective immediately, the minimum monthly salary for... [...]

China Withholding Tax Deferral Policy for Foreign Direct Reinvestment

Dividends derived from China by a foreign investor are currently subject to China Enterprise Income Tax in the form of Withholding Tax at 10%. In order to attract foreign capital flow into China, a preferential tax deferral policy has recently been implemented by the Chinese government... [...]

Double tax treaty for between Cyprus and Saudi Arabia

The Cyprus Ministry of Finance has announced that Cyprus has entered into a double tax agreement with Saudi Arabia for the avoidance of double taxation (‘DTT’), which aims to prevent tax evasion. The DTT was signed on January 3, 2018, in Riyadh during an official visit of the President of Cyprus there... [...]

What the tax reform bill means for individuals

Passive H.R. 1, known as the Tax Cuts and Jobs Act, which both houses of Congress passed on Dec. 20, contains a large number of provisions that affect individual taxpayers. However, to keep the cost of the bill within Senate budget rules, all of the changes affecting individuals expire after 2025... [...]

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