June 14, 2022

European Commission recommends action on ‘Golden passport’ and Golden Visas’

  Are the days of Citizen by Investment over? Is the end near? 28 March 2022, the European Commission issued a recommendation urging states to immediately repeal any existing Citizenship-by-Investment (CBI) schemes and to ensure that strong checks were in place to address the risks posed by Residence-by-Investments (RBI)schemes. It further recommended that member states …

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France is the very opposite of a tax haven

We have written extensively about French taxation – https://htj.tax/?s=france+tax Tax residence – domiciled fiscal is a criterion for tax liability – a foyer, business activity or centre of economic interest in France. The devolution of a resident’s estate is strictly regulated by law, with some exceptions for foreign nationals. Lifetime gifts are not tax–exempted. Life …

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Court of Justice finds Spain in breach of EU law over overseas assets’ declaration

  27 January 2022, the Court of Justice of the European Union (CJEU) ruled that Spain’s legislation requiring Spanish tax residents to declare their overseas assets or rights is contrary to EU law because it imposes restrictions on the free movement of capital. Under the Spanish legislation at issue, Spanish residents who fail to declare …

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Trinidad and Tobago Court of Appeals rules that dividend scheme was ‘treaty shopping’

  Today’s reflection…. Action 6 of BEPS introduced the principal purpose test (PPT). It is one of the minimum international tax standards applicable by countries members of the BEPS Inclusive Framework The PPT aims to tackle treaty abuse including treaty shopping  1. Subjective element: Tax administrations need to reasonably conclude, having taken into account all …

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