IN454 - Cross-Border Mergers in the EEA: Potential Advantages and the Need to Act Soon if a UK Company is Involved
With increasing political uncertainty across the world, particularly at the current time in the EU, a cross-border merger can be used as a way to secure business from one country in the European Economic Area (EEA) to another country in the EEA.
The Cross-border Merger Option Available to EEA Countries
For companies resident in EEA states, including the UK, the option of a ‘true’ merger … more
Please note that as a general principle EU citizens are free to move to other EU countries. Switzerland is in the Schengen Area and as such EU citizens can move there and vice versa. Unless specified, the residence schemes are therefore applicable to non-EU individuals for the countries featured. St Kitts & Nevis is not in the EU and therefore their scheme applies to EU and non-EU individuals. … more
Cyprus is rapidly expanding its tax treaty network, as illustrated by new treaties with Bahrain (coming into force January 2017) and Latvia (ratified June 2016).
In addition, in November 2016, Cyprus and India signed a revised Double Tax Treaty. Comprehensive details of the treaty are yet to be released but a number of key measures have been confirmed.
Key Provisions of the Treaty
Once the … more
IN446 - United Kingdom and United Arab Emirates Double Taxation Agreement - Potential Action to Consider
On 12 April 2016 the United Kingdom (UK) and the United Arab Emirates (UAE) signed a Double Tax Agreement (DTA). This is the first DTA to be signed between these two countries. The agreement is yet to come into force and requires ratification by both countries.
The DTA contains provisions regarding the location of corporate residence which may have important implications for a number of … more
With the increasing movement around the world of business people and wealthy individuals, for either commercial or personal reasons, there is an increased need for the provision of a base outside individuals’ countries of origin and outside of their countries of acquired residence to coordinate the development of business interests.
A Tax Neutral Base
A base is often most appropriately … more
Small and medium sized enterprises (SMEs) are frequently encouraged to grow their businesses by exporting or expanding abroad.
Taking the first steps into the international market can be daunting. Connecting with the right people is key to success in international trade and investment. The problem for SMEs can be how to make these contacts.
The Best Approach to Develop International … more
IN419 - Restarting the Clock for UK Non-Domiciles and Alternative Residence Options to Help Maximise Days Spent in the UK
The UK non-dom regime remains an attractive option for individuals seeking to move from their country of origin or current location. UK non-domiciles continue to have the opportunity to enjoy significant tax advantages for a period of up to 15 years.
Changes to UK Non-Dom Legislation
However, major reforms regarding how non-UK domiciliaries (“non-doms”) are taxed were implemented in April 2017. … more
The Common Reporting Standard (CRS) is based on FATCA principles and will result in a substantial increase in the flow of cross-border personal financial information.
FATCA (Foreign Account Tax Compliance Act) was introduced by the United States in 2010. FATCA requires financial institutions outside the US to report information regarding financial accounts held by their US clients to the … more
Dixcart is delighted to announce the establishment of Dixcart Domiciles to assist individuals seeking to move overseas.
There are many reasons why individuals and their families may wish to move abroad. Increased ease of travel is often a prime motive. Alternatively individuals and their families may wish to start a new life elsewhere or want the reassurance of being able to move to another … more
There are many reasons why individuals and their families may wish to consider the visa and passport options available from other countries. Increased ease of travel is often a prime motive. Alternatively individuals and their families may wish to start a new life elsewhere or want the reassurance of being able to move to another jurisdiction, at short notice, if circumstances within their own … more
The OECD confirmed the final package of measures regarding the OECD G20 Base Erosion and Profit Shifting (BEPS) initiative on 5 October 2015.
The OECD objective is to address the gaps and mismatches where corporate profits have been “disappearing” or shifting to low or zero tax jurisdictions, where no real value creation has taken place.
This Article summarises the various reports that have … more
Dixcart Domiciles can assist individuals and their families to gain residence in a number of different countries, and in some cases it is possible for citizenship to also be obtained.
A number of case studies are detailed below, outlining situations where Dixcart has been able to help individuals who were either seeking to move overseas, wishing to have an option to move abroad in the future, … more
Download our Dixcart Domiciles Brochure in Spanish
BEPS and Issues that Dixcart has been Identifying for Some Time
Substance based transactions - Base Erosion and Profit Shifting (“BEPS”) is coming!
For the past 10 years Dixcart has been actively encouraging clients to undertake substance based transactions, and guiding fellow professionals on how to move forward. Dixcart clients have been provided with operational business solutions and … more
IN353 - EU Freedom of Establishment Provisions Upheld Versus a Challenge from an EU Member Tax Authority
The recent first tier tax tribunal case ‘Fisher & Ors Fisher’ has dealt a blow to both UK Transfer of Assets Abroad (“TAA”) Legislation and to Gibraltar.
Mr and Mrs Fisher and their son Peter had a UK bookmaking business. They established a Gibraltar company to which they sold their telebetting business.
The UK tax authorities raised assessments to tax the Fishers under UK TAA … more
ECOFIN has Reached Political Agreement on an Amendment to the Parent-Subsidiary Directive
The Parent-Subsidiary Directive (2011/96/EU), adopted in November 2011, is intended to ensure that profits made by cross-border groups are not taxed twice, and that such groups are thereby not put at a disadvantage compared to domestic groups. It requires member states to exempt profits that have been … more