International Tax For SMEs September 2011 Abbreviatedsarogers99
These slides were used in a presentation given to attendees at a recent UKTI / Natwest / Francis Clark LLP seminar in Salisbury - How to Open Up New Markets Overseas.
DMIEXPO - Arosal - Where To Hold Your IP: The A To Z Guide For Digital MarketersMorning Dough
Arosal will walk you through the challenges and pitfalls which characterize the global tax scene post-BEPS, specifically as regards IP Boxes and the so-called ‘Nexus’ approach. We shall walk you through the process of registering and protecting your IP, whilst designing a robust international structure which will stand up to any BEPS-related challenge.
Furthermore, Arosal will outline the services which you will require, and the process through which these will be obtained regarding the implementation of your structure, whilst focusing on the tax optimization of the group’s entire structure as concerns all types of taxes. Finally, we shall discuss the administration of your international structure, and comment on the way forward in the global market place.
Key Facts for Limited Companies in Malta; a legitimate low tax EU jurisdiction
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
Guide "Make a French Start" : The French tax systemNicolas Ribollet
Guide "Make a French Start" : The French tax system
Mazars and Business France combined their expertise to help foreign investors and entrepreneurs who want to settle in France. Mazars has created practical guides that we hope will provide you with valuable insight to launch and grow your business in France.
Argentina Clarifies Income Tax ProvisionsNair and Co.
Argentina has, during the recent past, published amendments to income tax provisions. Certain clarifications have been recently issued relating to these amendments
International Tax For SMEs September 2011 Abbreviatedsarogers99
These slides were used in a presentation given to attendees at a recent UKTI / Natwest / Francis Clark LLP seminar in Salisbury - How to Open Up New Markets Overseas.
DMIEXPO - Arosal - Where To Hold Your IP: The A To Z Guide For Digital MarketersMorning Dough
Arosal will walk you through the challenges and pitfalls which characterize the global tax scene post-BEPS, specifically as regards IP Boxes and the so-called ‘Nexus’ approach. We shall walk you through the process of registering and protecting your IP, whilst designing a robust international structure which will stand up to any BEPS-related challenge.
Furthermore, Arosal will outline the services which you will require, and the process through which these will be obtained regarding the implementation of your structure, whilst focusing on the tax optimization of the group’s entire structure as concerns all types of taxes. Finally, we shall discuss the administration of your international structure, and comment on the way forward in the global market place.
Key Facts for Limited Companies in Malta; a legitimate low tax EU jurisdiction
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
Guide "Make a French Start" : The French tax systemNicolas Ribollet
Guide "Make a French Start" : The French tax system
Mazars and Business France combined their expertise to help foreign investors and entrepreneurs who want to settle in France. Mazars has created practical guides that we hope will provide you with valuable insight to launch and grow your business in France.
Argentina Clarifies Income Tax ProvisionsNair and Co.
Argentina has, during the recent past, published amendments to income tax provisions. Certain clarifications have been recently issued relating to these amendments
0% tax - how significant tax savings can occur using Malta's Remittance System
A legitimate low tax EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
UAE can be used favorably as the location for the ultimate holding company for a group that is relocating to a new jurisdiction or on formation of a new publicly traded entity with worldwide activities
Francis Clark is pleased to invite you to our fourth annual innovation and technology conference which is taking place at the Exeter University Innovation Centre.
The morning will bring together a number of topical issues to those involved in innovation and technology, from start-ups to multi-million pound turnover businesses. There will also be an opportunity to hear more about the Innovation Centre itself, and during the morning we will be offering a tour around the 'Centre for Additive Layer Manufacturing' on the University campus.
Investing in Panamá es una publicación elaborada por la consultora Casin, referente del Outsourcing Administrativo, Contable e Impositivo de Panamá y por Santa Fe Associates Internacional para que cualquier interesado en invertir en Panamá tenga una primera información resumida sobre los aspectos que pueden interesarle de este país.
Where we came from
Numbers…and why we don’t care about them!
What we are good at…and why!
Our passion about tax
What others think about us
Who do we work with
Our focus on knowledge
Taxpayers are encouraged to heed the advice of the IRS and file undisclosed assets with the government through the Overseas Voluntary Disclosure Program while it is still available.
The Foreign Account Tax Compliance Act (FATCA) will be taking place on 17-20 November, in Dubai, UAE will help financial institutions successfully implement and comply with FATCA in their organisation by providing implementable insights and tools to effectively review pre-existing accounts, identify US accounts and onboard new entities clients through 4 in-depth workshops, presentations and panels.
For more information on this conference visit: http://www.informa-mea.com/fatca
Sponsored by our partners at Taxwise and Ashfords, this event consists of a variety of topics that our clients are telling us are giving them the biggest challenges.
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
0% tax - how significant tax savings can occur using Malta's Remittance System
A legitimate low tax EU jurisdiction.
5% effective corporate tax rate, no withholding, capital gains or entry or exit taxes. No inheritance or wealth taxes.
UAE can be used favorably as the location for the ultimate holding company for a group that is relocating to a new jurisdiction or on formation of a new publicly traded entity with worldwide activities
Francis Clark is pleased to invite you to our fourth annual innovation and technology conference which is taking place at the Exeter University Innovation Centre.
The morning will bring together a number of topical issues to those involved in innovation and technology, from start-ups to multi-million pound turnover businesses. There will also be an opportunity to hear more about the Innovation Centre itself, and during the morning we will be offering a tour around the 'Centre for Additive Layer Manufacturing' on the University campus.
Investing in Panamá es una publicación elaborada por la consultora Casin, referente del Outsourcing Administrativo, Contable e Impositivo de Panamá y por Santa Fe Associates Internacional para que cualquier interesado en invertir en Panamá tenga una primera información resumida sobre los aspectos que pueden interesarle de este país.
Where we came from
Numbers…and why we don’t care about them!
What we are good at…and why!
Our passion about tax
What others think about us
Who do we work with
Our focus on knowledge
Taxpayers are encouraged to heed the advice of the IRS and file undisclosed assets with the government through the Overseas Voluntary Disclosure Program while it is still available.
The Foreign Account Tax Compliance Act (FATCA) will be taking place on 17-20 November, in Dubai, UAE will help financial institutions successfully implement and comply with FATCA in their organisation by providing implementable insights and tools to effectively review pre-existing accounts, identify US accounts and onboard new entities clients through 4 in-depth workshops, presentations and panels.
For more information on this conference visit: http://www.informa-mea.com/fatca
Sponsored by our partners at Taxwise and Ashfords, this event consists of a variety of topics that our clients are telling us are giving them the biggest challenges.
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
Ireland is an advantageous location for holding companies, due to:
- Favourable tax treatment of dividend income;
- No Withholding Tax on dividends from Irish Holding Company to EU / tax treaty countries;
- No Capital Gains Tax on disposal of shareholdings in subsidiaries;
- Favourable tax regime for R&D / intangibles;
- Tax deductions for interest on borrowings;
- Favourable Withholding Tax regime for interest and royalty payments
- & more...
As the WFO provider with the highest customer satisfaction ratings of any vendor in our industry, we are announcing ZOOM 5.8!
Best-in-Class Cisco™ Finesse Integration, Embedded Performance Analytics with the Fastest Time to Value, and More.
Quick overview of Ardyss for new distrubutors
Do any of these appeal to you or anyone you know?
. Starting your own business.
. Working from home.
. Flexible hours to suit other work and family life.
. Low and affordable start-up costs.
. Great earnings and compensation plan.
An appointment with Ardyss will change your life! Join us and become an independent distributor.
http://www.ucheejike.blogspot.com/
Infographic: Sales Channel Incentive Fraud Trends For 2014360insights
Here are the top and emerging trends in channel and consumer promotion incentive fraud. The data are pulled from over 16M sales channel incentives and consumer rebate claims.
Too many people view partnerships as a form of sales. While similar, partnerships are much more involved. Here are a few tips for cultivating strategic partnerships that can generate growth and lead to long term revenue growth.
Case Study (Presentation): How Cisco Spark is used at ZOOM InternationalZOOM International
This case study is available in written text (PDF) and slide format. It explains how ZOOM uses Cisco™ Spark, ZOOM WFO, Salesforce.com™, Cisco Tropo, Cisco Voice Platforms, and Cisco Webex to help achieve the #1 rank in customer satisfaction for the WFO industry.
The studies include details on the background, problem, solution, and results of ZOOM's customer-focused culture, people, process, and technology.
Fund Regulation - Global Perspectives' Key Updates for 2015 GECKO Governance
This Fund Regulation 2015 update covers key updates from the main pieces of regulation impacting the investment fund industry this year.
Key regulatory updates include:
• AIFMD: update on Annex IV Reporting, Authorisation, Key dates in 2015
• FATCA: latest news from the IRS and key dates ahead, as well as CRS update
• UCITS V: progress on with implementation (remuneration & depositary) and key points to consider
• EMIR: latest requirements for reporting and implementation
• Solvency 2: impact on asset managers in the year ahead
• MiFID 2: update on MiFID reporting (MiFIR), fee disclosure and the impact on research
• How Global Perspectives can assist with your operational regulatory requirements
Contact us for more information:-
Shane@globalperspective.co.uk
IBSA Webinar on FATCA & Exchange of Information which took place on 27 January 2015. Presented by Ross Belhomme of Saffery Champness (Geneva) and Peter Grant of KPMG (London). To view the webinar on demand, please visit our Bright Talk channel at https://www.brighttalk.com/channel/11641
4 Essential Tasks to Prepare for FATCA - Global Perspectives White Paper - Oc...GECKO Governance
Time is marching on and the deadlines for FATCA are getting closer. In July 2013 the IRS postponed FATCA implementation for 6 months. Many companies relegated FATCA to the back of the regulatory queue to focus on Dodd Frank, AIFMD, Solvency II and a myriad other regulatory initiatives demanding their attention.
It’s time to focus on FATCA again. The 6 month grace period should be used to prepare for FATCA. fact the delay should serve to underline the scale of the work involved worldwide for both financial institutions and regulators themselves, in order to implement FATCA’s requirements.
In this white paper we will look at the 4 essential steps companies need to complete to prepare for FATCA.
This is the first in a series of Global Perspectives white papers which will cover what is required to prepare, implement and maintain compliance with FATCA in your organisation.
Sign up for all our free white papers on our website or by emailing:-
Shane@globalperspectives.co.uk
Attached is the May 2021 publication of the Technical Brief for Investment Funds, a newsletter developed by the Loeb Smith Cayman Islands Investment Funds Technical Team. As regulatory compliance becomes increasingly a key focus for both Cayman investment funds and CIMA as regulator, this Technical Brief covers, among other things:
FATCA/CRS Summary and Update
Considerations for Directors of Cayman Regulated Open-ended Funds
Cayman Islands’ Rule on Cybersecurity for Regulated Entities
New Administrative Fines for breach of Regulatory Laws.
If you have any questions, please reach out to your usual Loeb Smith contacts or any member of our Investment Funds Technical Team shown in the Bulletin
Cordium held a webinar on 31st March 2016 Operating in the UK made easy for US Firms
For managers based in the US, the UK’s local regulatory, taxation and reporting regimes, can seem unfamiliar and feel like a serious barrier to entry to building a presence in the UK. Combine that with regulator-imposed capital requirements and labor-friendly employment legislation, the whole exercise can feel daunting and frustrating.
Cordium has a 20 year history of helping firms to find their way through the maze of local and cross-border issues. Over the years we have deployed our specialist compliance, reporting, tax and prudential resources to complement your internal teams, legal counsel and other advisers. Our clients have been able to start operating in London quickly, whilst being secure in the knowledge that they are compliant with all local requirements, and have a structure that ensures satisfaction of all initial and ongoing regulatory obligations. If speed-to-market is important, or FCA substance requirements are a challenge, Mirabella’s hosting solutions can solve the problem, whether as an indefinite solution or just as a stop gap until either FCA authorisation is granted or the business achieves commercial sustainability.
The webinar discussed the challenges of setting up and operating in London and how Cordium can make it easy.
Cordium was delighted to be joined by guest speaker Karthik Iyer who is the Asset Management and Capital Markets Lead at UK Trade & Investment, a UK government body focussed on inward investment into the UK.
The presentation was followed by a live question and answer session.
This was a presentation to NJTC audience - a Government delegation on Financial Innovation & Supervision, with Tax Evasion, Tax Transparency and how FATCA, CRS solutions addresses tax transparency.
Buy-side chair Organized Trade Execution Exchange No 05369106 WS-I Transitions to OASIS Akadimias 81 PC 10678 E.D.GOUTOS SA.
Government Administration Managing LOU LEI: (AIFMs), Department Member … EUROPÄISCHE KOMMISSION (Registrierungsnummer : 2016/072505) SA.45289(2016/MI) Authorized Economic Operator (ΑΕΟ) E.D. GOUTOS S.A. NCAGE cod: CM200 E.D.GOUTOS.SA. ΝΑΤΟ ARMY GR ΑΡΘΡΟ 5 HRB 68648 ΝΕΟ ΕΛΛΗΝΙΚΟ ΝΟΜΙΣΜΑ EG Credit Central Bank of Cyprus SIC 8888 LEI YUV8PRHOZSRFRC4JO269 and Register Ministry AG HRB68648 = 5299 00 PH63HYJ86ASW55 Cross border ...Address: Ar.G.W.MI. 0000931106 HELLENIC REPUBLIC EIN/TIN - SIC 8888 https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&SIC=8888&owner=include 0000931106. EIN/TINNEW GLOBAL OPEN WEB E BANKING MARKET HANDLING INTERNATIONAL GREEK CHARGES GR0112005674 E.D.GOUTOS SA Postleitzahl 21300 Ort PORTOCHELI GREECE Staat Vereinigte Staaten von Amerika Steuernummer/USt-IdNr. 93172860596 Sitz des Geldinstitutes GREECE Bankleitzahl (Sortcode)
A synopsis of the Financial Conduct Authority’s (FCA) latest news and publications issued in April and May 2018.
With GDPR and MiFID II processes now firmly embedded in our daily lives, many of our readers will look back at the months of April and May with a sense of relief.
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
International Tax Planning after BEPS - A Country SpotlightTIAG_Alliance
The OECD initiative against “Base Erosion and Profit Shifting” was
commissioned by the G-20 in 2013. Final deliverables were presented to the G-20 in November 2015.
“Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs.)”
Creators and Presenters:
• Russell Brown, LehmanBrown, China
• Florence Bastin, Fiduciaire du Grand-Duché de
Luxembourg S.à r.l. (FLUX)
• Fabrice Rymarz, Racine, France
• Simone Hennessy, HSOC, Ireland
• Fuad Saba, FGMK, Chicago, USA (Moderator)
UAE introducing VAT from January 2018 and this presentation gives full information regarding VAT concepts and applicability. Drop your query to us to discuss more about VAT in UAE at vat@nrdoshi.ae
The implementation of the Foreign Account Tax Compliance Act (FATCA) on July 1, 2014, marked a major change in the “rules of the game” for international tax cooperation, posing serious operational and systemic challenges for foreign financial institutions (FFIs). One of the most complex challenges is the need for FFIs to gather sensitive client data to identify accounts for the purpose of reporting to the Internal Revenue Service (IRS).
Peter Walton-'La complejidad de las Normas Internacionlaes de Información Fin...Fundación Ramón Areces
El 11 de febrero de 2016, la Fundación Ramón Areces acogió una conferencia de uno de los mayores expertos en las Normas Internacionales de Información Financiera (NIIF). Peter Walton, catedrático de Economía Financiera y Contabilidad de la ESSEC Business School (París) y director del ESSEC Financial Reporting Centre, habló de la 'Complejidad en las NIIF, rendimientos decrecientes y diferencias en la contabilidad'. La conferencia formó parte del V Ciclo sobre 'Regulación contable internacional', organizado por la Fundación Ramón Areces en colaboración con la Cátedra UAM-Auditores Madrid de Información Financiera Corporativa.
Peter Walton-'La complejidad de las Normas Internacionlaes de Información Fin...
FATCA - What to Do Now
1. FATCA – What to do now
By Tim Andrews,
Service Development Director
IPES PRIVATE EQUITY UPDATE EDITION 17
Foreign Account Tax Compliance Act (FATCA) Reporting is due by mid
2015 and is here to stay. Fund Managers should beware of some pitfalls
in the process and, like Alternative Investment Fund Managers Directive
(AIFMD) Reporting, ensure that they minimise its impact on investors
and cost.
FATCA in 2014 – Classification and Registration
FATCA, the attempt to eradicate tax evasion by US tax residents using
foreign accounts through information sharing between jurisdictions
and the US, rose up the agenda of Fund Managers in 2014 as it was
transposed into the law of most developed countries under Inter-
Governmental Agreements (IGAs). It therefore applies to all Foreign
Financial Institutions (FFIs) both within and outside the United States,
irrespective of whether they transact in US Dollars, have US Investors or
own US portfolio companies.
In practice, FATCA is a 4 stage process whereby Managers must classify
each entity in their Funds into a number of ‘buckets’ which determine
whether the entity must be reported to the local tax authority. If an entity
is to be reported then the manager had to obtain a Global Intermediary
Identification Number (GIIN) by 31 December 2014.
FATCA has been applied in practice by multiple Regulators, each with their
own guidance, systems and legislation. As with AIFMD, most European
authorities have scrambled to adapt their systems to accept the required
reports in XML format and have published and updated their guides – not
always in English.
Recently HM Revenue and Customs (HMRC) clarified that the top holding
company in an investment structure should not be classified as reportable.
ThishaslongbeenadiscrepancywithotherModel1IGAcountriessuchas
Guernsey and Luxembourg and now leaves some managers deregistering
some holdcos that no longer have to report. Some jurisdictions, such as
Luxembourg, require nil returns on the basis that if you do not report, how
can the authorities ensure compliance? Other jurisdictions, like the UK, do
not require nil returns, at least for now. Overall, remaining compliant is
harder than it should have been.
FATCA in 2015 – Due Diligence and Reporting
Having classified their structures and obtained their GIINs, many
Managers are in the midst of reviewing their CDD on existing investors
against the indicia specified under FATCA. Funds must determine whether
their investors are reportable under FATCA as US taxpayers or, if the Fund
is domiciled in the UK or Crown Dependencies, under ‘UK FATCA’ as UK
taxpayers. Getting this decision wrong exposes the board of the General
Partner to risks of non compliance or to the inadvertent reporting of
investors to the tax authorities.
Short term, many houses have relied on paper systems to obtain and
evaluate the required information. This has led to a wide array of
paper forms which can leave investors uncertain. A systemised and
standardised approach is clearly necessary across the industry to reduce
duplicative effort. Managers should also ensure that each investor self
certifies the accuracy of the information that they provide so as to limit
their own exposure.
Reporting – Another XML Submission
Once the due diligence on each investor has been reviewed, those that
are reportable as US taxpayers need to be reported to the tax authority
in the domicile of the fund by 30 June 2015. Under ‘UK FATCA’ reporting
will be due by 31 May and will begin in 2016 on data from both 2014
and 2015. Managers therefore face a calendar of tax reporting alongside
the AIFMD Reporting that many have had to begin submitting recently.
While, like AIFMD, FATCA is a prescribed reporting format, the experience
of multiple user guides and interpretations suggests that significant
variation will emerge in both content and submission method over time.
In a bid to set a standard for legislation and reporting, the OECD recently
published the Common Reporting Standard (CRS) which will be in place
by 2017. More than 90 countries have signed up to the CRS of which 58
will adopt it in 2017 and the remainder in 2018. The tax information
exchange that started with FATCA is therefore here to stay and will
become increasingly global over the coming years.
What to do now:
1. If you have not started classifying and registering it is not too late in
practice. Do it now to ensure that you remain compliant with local
legislation.
2. Ensure that you or your provider has an efficient, systematic process
to minimise cost, investor hassle and risk of error.
3. Ask questions. This process is new for tax authorities, service providers
and managers alike. There is no such thing as a silly question.
4. Embed the process. FATCA will apply to all new Funds and investors
and should be built into Fund documents, due diligence and the
reporting cycle.
5. Look ahead. The CRS requirements are similar but not identical to
FATCA. Ask the questions from investors now to avoid repeating the
process in future.
There is a lot of confusing content out there. If you would like to discuss
FATCA or AIFMD Reporting in greater detail we would be happy to
talk further.
Tim Andrews
Service Development Director
T: +44 (0)1481 735826
E: tim.andrews@ipes.com
W: www.ipes.com
2015 2016 2017
01/07/2014
New investor
onboarding
procedures in
place
31/12/2014
Registration for
all FFIs complete
30/06/2016
CI + Cayman FFIs
US reporting for
2014 + 2015
30/06/2016
DD on all pre-
existing investors
complete
30/06/2015
CI + Cayman
FFIs reporting
for 2014
30/06/2015
DD on pre-existing
high value FFI
investors complete
31/05/2015
UK FFIs US
reporting for
2014
FATCA Timeline
Ipes (UK) Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales with No.5648495 at 10 Lower Grosvenor Place, London, SW1W 0EN. VAT Registration No. 882 3503 21. Ipes (Guernsey) Limited is
regulated and licensed by the Guernsey Financial Services Commission under the Protection of Investors (Bailiwick of Guernsey) Law, 1987 as amended. Registered in Guernsey with No.33475 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey
GY1 2HL. Ipes (Jersey) Limited is regulated by the Jersey Financial Services Commission under the Financial Services (Jersey) Law 1998. Registered in Jersey with No.99112 at Third Floor, South Tower, 29/31 Esplanade, St Helier, Jersey JE4 0ZS. Ipes
(Luxembourg) S.A. is licensed by the Ministry of Finance per authorisation no.30/10 and is regulated by the Commission de Surveillance du Secteur Financier to provide various administration services under the Financial Sector Act of 5 April 1993 (as
amended). Registered in Luxembourg RCS with No. B 150156 at 2-8, Avenue Charles de Gaulle, L-1653 Luxembourg.
Ipes has taken all reasonable steps to ensure that information contained herein has been obtained from reliable sources and that this publication is accurate and authoritative in all respects. However, it is not intended to give legal, tax,
accounting or other professional advice. If such advice or other expert assistance is required, the services of a competent professional should be sought.