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  • IN576 Key Measures Relating to EU ATAD Now Implemented in Malta

    As a member of the EU, Malta has implemented the EU Anti-Tax Avoidance Directive (ATAD) and has incorporated it into domestic legislation.

    Malta incorporated the ATAD measures into its domestic legislation at the beginning of December 2018 through implementation of Legal Notice 411, which includes the following:

    an interest limitation rule;

    general anti-abuse rules (GAAR);

    controlled … more

  • IN575 Increased Cash Rebates Film Production in Malta

    Background

    The Maltese Government is committed to promoting the film production sector and cash rebates can be claimed, as a financial incentive, to the growing Audio-visual Industry in Malta.

    What Rebates are Available?

    Starting from January 2019, qualifying companies can receive a maximum 40% cash rebate for film production in Malta.

    The cash rebates are rebates on the expenses in Malta, … more

  • IN577 Luxury Assets such as Aircraft and Yachts and Preparation for Brexit

    Aircraft and Yacht Registration and VAT Considerations

    The recent political upheaval with the United Kingdom leaving the European Union (Brexit) at the end of March 2019, has left many yacht and aviation owners with a potentially unquantified problem (both financially and legally).

    The VAT and registration (aircraft and/or yacht) arrangements in place before Brexit, may need consideration and … more

  • IN571 Routes To UK Residence And Citizenship

    Individuals granted a Tier 1 (Entrepreneur) visa or Tier 1 (Investor) visa under the existing rules before/on 28 March 2019 are generally unaffected by the new rules effective from 29 March 2019. For more information, please refer to Dixcart Article: IN580 Reforms to UK Investor Visa Category and New Entrepreneur Visa Routes

    Who Can Move to the UK?

    EEA nationals and their family members have … more

  • IN572 Individual Taxation In The UK

    Liability to UK tax is broadly determined by the application of the concepts of "domicile" and "residence".

    Domicile

    UK law relating to domicile is complex and differs from the laws of most other countries. Domicile is distinct from the concepts of nationality or residence. In essence, you are domiciled in the country where you consider you belong and where your real and permanent home is. … more

  • IN570 Armed Guards To Be Allowed On Board Portuguese Flagged Ships - Where Piracy Is Prevalent

    New Law

    On 10 January 2019, the Portuguese Council of Ministers approved a law to allow armed guards to sail on Portuguese flagged vessels.

    This measure is long-awaited by the International Shipping Registry of Madeira (MAR) and by ship owners registered within it. The increase in financial loss due to hijackings and ransom demands, and the risk to human lives, as a result of hostage taking has … more

  • IN569 Using Switzerland For Asset Protection In An Increasingly Challenging World

    Background

    Switzerland is an incredibly attractive jurisdiction for international companies and high net worth individuals, seeking stability (political and economic).

    Taking into account the many factors that influence the choice of jurisdiction, the case for Switzerland is a strong one.

    Reasons Why Switzerland is a Favoured Location

    Political, financial, social and economic stability … more

  • IN568 Portuguese Golden Visa - Investment Route And The Non-Habitual Residents Regime

    Background

    Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe.

    Portugal is increasingly recognised as an international hub with 71 Double Taxation Agreements and 49 Investment Protection Treaties.

    The Golden Visa

    The Portuguese … more

  • IN567 Moving To Italy - The Resident Non-Domiciled Tax Regime

    Background

    During 2017 the Italian Government introduced a new tax regime: The Resident Non-Domiciled Tax Regime (also known as the "Flat Tax Regime"), with the aim of attracting high net worth individuals who want to relocate to Italy. 

    The new legislation introduced a key change to the general principle of worldwide taxation for Italian tax residents. According to these provisions an … more

  • IN566 Significant Tax Advantages Available To Individuals Moving To Guernsey

    Background

    Guernsey is one of the Channel Islands and is situated in the English Channel, close to the French coast of Normandy.

    Whilst retaining very close links to Britain, Guernsey is independent from the UK and has its own democratically elected parliament which controls the island's laws, budget and levels of taxation.

    What Tax Advantages are Available to Individuals Moving to Guernsey? … more

  • IN518 - Why the Madeira International Shipping Register (MAR) is so Attractive and the Advantages of Registering a Vessel in Madeira

    Background

    The objective of the Madeira International Shipping Register (MAR) is to offer a credible alternative to other international registers. The high quality and safety standards of a conventional register have been maintained within an attractive tax environment designed to encourage inward investment to the island of Madeira. Vessels registered with MAR carry the Portuguese flag and are … more

  • IN450 - A Move of Residence

    Last Updated: July 2019

    Please note that as a general principle EEA citizens are free to move to other EEA countries. Switzerland is in the Schengen Area and as such EEA citizens can move there and vice versa. The residence schemes detailed (excluding St Kitts & Nevis) are therefore applicable to non-EEA individuals for each of the countries featured.

    Please note, however, that where freedom … more

  • IN563 The Option of A Second Passport - St Kitts & Nevis Citizenship by Investment

    Individuals and families are becoming increasingly mobile and the ability to hold a second passport is becoming more relevant. The Caribbean is an attractive destination for a number of reasons, including the relaxing lifestyle, beautiful scenery and the climate. There are also opportunities to hold a second passport, even if the immediate intention is not to relocate to the Caribbean.

    Why do … more

  • IN565 Why Use The Azores (Portugal) For Yacht Importation?

    Background

    The Archipelago of the Azores is composed of nine volcanic islands and is situated in the North Atlantic, about 1,500 kilometres west of Lisbon. These islands are an autonomous region of Portugal.

    What Advantages are Offered by the Azores for Yacht Importation into the EU?

    The standard rate of Portuguese VAT is 23% but the Azores benefits from a reduced VAT rate of 18%.

    In … more

  • IN562 New Substance Requirements For Isle Of Man Companies - Effective 1 January 2019

    The Isle of Man Treasury has published a draft of the proposed Income Tax (Substance Requirements) Order 2018. This draft Order will, once final, and if approved by Tynwald (in December 2018), have effect in respect of accounting periods commencing on or after 1 January 2019.

    This means that from January 2019, companies engaging in “relevant activities” will have to demonstrate that they meet … more

  • IN564 Update: The Proposed Tax Reform Of Swiss Companies

    Background

    Reform of the taxation of Swiss companies has been on the agenda for a considerable length of time. On 28 September 2018, the final draft of the Federal Act on Tax Reform and "AHV" Financing ("TRAF") was approved by the Swiss Parliament.

    AHV is an obligatory payment for every individual over the age of 20 living in Switzerland. It is an insurance for old age and/or for the bereaved. … more

  • IN561 Key Aspects - Economic Substance Requirements For Guernsey

    1 Introduction

    Like other offshore jurisdictions, Guernsey will be implementing new legislation introducing economic substance requirements for companies in Guernsey. This briefing note sets out key aspects of the Guernsey Government proposed legislation,  noting that further, more comprehensive guidance notes, will follow in due course.

    The proposed legislation is relevant to all companies … more

  • IN558 Guernsey And The Isle Of Man - Implementation Of Substance Requirements

    Background

    The Crown Dependencies (Guernsey, Isle of Man and Jersey) have introduced economic substance requirements, for companies incorporated, or resident for tax purposes, in each of these jurisdictions, effective for accounting periods starting on or after 1st January 2019.

    This legislation has been designed to meet the high level of commitment made by the Crown Dependencies, in November 20 … more

  • IN560 UK 'Representative Of An Overseas Business Visa' Key Advantages And General Requirements

    Background

    As detailed in a number of previous Information Notes, there are several different UK visa options available to non-EEA nationals, to come to the UK to live and work.

    What is a ‘Representative of an Overseas Business Visa’?

    The “Sole Rep Visa” as it is informally known, is a route designed for senior employees who are non-EEA nationals, enabling them to move to the UK and establish … more

  • IN556 The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

    Background

    The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018.

    Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018.

    This new treaty, follows current OECD standards, including Base Erosion and Profit Shifting (BEPS) … more