The new year 2017 has started for Uruguay with much less privacy that the previous one. In December 2016 Uruguay’s Parliament approved the Fiscal Transparency Bill, which, on the one hand, eliminates bank secrecy for fiscal purposes and, on the other hand, puts an end to the anonymity of corporations and other legal entities.
Taking into account that international standards are strongly influenced by fiscal transparency and anti-money laundering, these changes are not surprising. The growing demand for global transparency and control of capital flows anticipated this bill, non-collaboration with the international system would mean isolation on several fronts.
The Angolan government imposed a special contribution tax at 10% on any transfers pertaining to the value of payments for technical assistance and management services rendered by non-residents since mid-2015.
Given the characteristics of the special contribution tax and the economic situation in Angola, the objective of the regime were two-fold: enhance Angolan tax revenue and help retain capital in Angola by reducing payments to foreign entities.
Hong Kong is now challenging the tax substance of special purpose vehicles (SPV) such as intermediate holdings and this is producing great troubles for some companies.
If the Hong Kong Tax Residence Certificate (TRC) is denied by the Hong Kong Inland Revenue Department (IRD), it might eventually trigger the imposition of withholding tax when paying dividends to the holding company.
The IRD issued rules for obtaining a certificate of Hong Kong residence status had been effective since 1st February, 2015. This certificate is provided by the Hong Kong authorities to a resident which allows the resident to claim tax benefits under the Double Taxation Agreements (DTAs). The rules make it more difficult to obtain them.
The Hong Kong trust industry is comprised of four main types of trust, namely corporate trusts, private trusts, pension schemes and charitable trusts.