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The following summary of the Malta Discussion Group meeting highlights the impact of intellectual property on the value of companies and the tax efficient structures that can maximise its exploitation.
Against our hopes but in line with the most recent polls, 59% of the Swiss population today voted against the 3rd Swiss corporate tax reform which means that the reform will not be implemented in its proposed form. Although the outcome of today’s referendum is a clear and major setback in the long process of reaching consensus on the much-needed Swiss corporate tax reform, we remain confident that an attractive reform remains within reach. Such modified reform should be a lighter version of the proposal which failed to convince the population today.
Under current US law, for 2017, the estate and gift tax exemption will be $5.49 million per individual, up from $5.45 million in 2016. That means an individual can pass $5.49 million to his or her heirs and pay no federal estate or gift tax. Surviving spouses can port over each other’s unused exemptions, allowing a couple to shield just a little less $11 million ($10.98 million) from federal estate and gift taxes. For taxable estates, the rate is 40%. Assets passing at death get a “stepped up basis” that allows capital gains to escape taxation. If a person bought stock for $200,000 and it’s worth $2 million when he or she dies, the $1,800,000 appreciation escapes capital gains taxation—but could be subject to the estate tax depending on the value of the person’s estate (including taxable gifts made during the person’s lifetime).
Over the last 10 years we have seen major changes to the taxation of UK resident but non-domiciled individuals (“non-doms”) and from April next year we will see the introduction of further more radical changes which will substantially change the landscape in which non-doms will operate. In this article I set out some of these points to consider.
Many of you will be familiar with the Polycon case study, which I have often used to illustrate the issues involved in structuring the development of international companies. This was the basis of the recent IBSA annual conference at the Landmark hotel in London, and the issues that were raised were so varied and interesting that I thought I would summarise them – they epitomise the problems and opportunities when helping particularly medium sized companies develop their businesses internationally.
In our October 2015 newsletter, we discussed the Base Erosion and Profit Shifting (BEPS) project for which the OECD had just finalised their Action Points recommendations. Unlike EU’s legislation that has immediate effect when it becomes national law (which is obligatory for all EU Member States), or some federal legislation that is immediately transposed in the Member States’ jurisprudence, recommendations given by the BEPS Action Points are … only recommendations. However, in seeking to prevent multi-national corporations (MNCs) shifting profits from high tax to low tax jurisdictions and achieving unintended tax benefits, we have seen many countries enthusiastically implementing the BEPS proposals, including some non-OECD members.
The recent amendments to the Naturalisation of Investors in Cyprus by Exception Scheme, based on subsection (2) in Section 111A of the Civil Registry Laws of 2002-2015 was approved by the Cyprus Council of Ministers on the 13 September 2016.
On 10 May 2016 in Mauritius, representatives of the governments of India and Mauritius signed an agreement which provided the amendment of the provisions of the double tax treaty agreement that was signed between the two countries on 1983.
The Cyprus Tax Department has recently submitted for further discussion a Bill of Law at the House of Representatives, which refers to the mandatory digital submission of VAT returns via the system TAXISNET for companies, associations and other legal entities.
On August 2015, during the visit of the Iranian delegation to Cyprus; a double tax treaty agreement was signed between the two countries.