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Feature

Australia

  • Taxation of limited partnerships- Resource Capital Fund IV LP v Commissioner of Taxation [2018] FCA 41                                       

 

Case Summaries

European Union

  • European Court of Justice provides clarifications on concept of "wholly artificial arrangements" in joined cases Deister Holding (C-504/16) and Juhler Holding (C-613/16)

United Kingdom

  • Investec Trust v Glenalla Properties – the Privy Counsel strengthens the protections afforded to Guernsey trustees of Jersey law trusts
  • Without consultation or notice, decisions by majority trustees can bind the minority                                         

 

Legislative Developments  

Australia

  • Corporate Collective Investment Vehicle (CCIV) regime
  • ATO Targets Trusts and Private Groups
  • Australian Property Tax Updates
  • Australian Labour Party's Proposed Legislative Changes to Discretionary Trusts

China

  • China issues new rules on the interpretation and implementation of tax treaties

France

  • Real Estate Wealth Tax (IFI) (2018 Finance Act, art. 31)
  • Draft law on the fight against fraud
  • Introduction of a 30% flat tax for investment income and capital gains on sale of securities (2018 Finance Act, art. 28)
  • Social Security Finance Act for 2018: the employer-specific social contribution due on French-qualified restricted stock units (RSUs) reduced to 20% again (Social Security Finance Act for 2018, art. 11)
  • Introduction of a New "Macron 2018" social and tax regime applicable to French-qualified RSUs granted pursuant to shareholders authorization as from 1 January 2018 (2018 Finance Act, art. 28)
  • BSPCE: alignment of the exercise gain with the fiscal and social regime of the new "flat-tax" rate of 30% (2018 Finance Act, art. 28)

European Union

  • EU Parliament's Panama Papers Committee issues report and accuses EU Member States of being part of the problem

Hong Kong

  • Hong Kong - developments
  • Hong Kong adopts a two-tiered profits tax rates regime

Indonesia

  • Highlights of Tax Amnesty
  • The New CFC Rules
  • Limited Liability Companies Must Now Report Their Beneficial Owners
  • An Update on Automatic Exchange of Information

Malaysia

  • Malaysian legal and tax developments relevant to wealth planning
  • Malaysia signs BEPS Multilateral Convention
  • Malaysia Issues Updated Mutual Agreement Procedure Guidelines
  • Clarification on tax audits

Netherlands

  • Dutch Government announces implementation of the ATAD, conditional withholding taxes and an update on substance requirements

Philippines

  • Philippine developments

Singapore

  • Tax highlights of the Singapore budget 2018

Spain

  • New criteria in Spain to establish tax residency

Switzerland

  • Overview of recent developments

Taiwan

  • Overview of recent developments

Thailand

  • Overview of recent developments

United Arab Emirates

  • The UAE takes further steps to boost foreign investment

United Kingdom

  • Changes to UK Partnership Taxation Rules

United States

  • End of Offshore Voluntary Disclosure Program
  • More Partnership Audit Regulations

Venezuela

  • Venezuela issues law amending regime applicable to foreign investments in the country
  • Exchange rate for Venezuelan customs obligations under Exchange Agreement No. 39
  • Monetary restructuring decree introduces new exemptions from VAT and income tax

 

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