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.
Donald Trump’s election as the USA’s 45th president combined with continued Republican control of both the House and Senate will almost surely result in passage of a major tax cut in 2017. Although the size and design of that measure and how it shall be funded are remained uncertain, it is worthy to understand the key aspects of his tax plan, consider if they have implications for you as a taxpayer, and well-prepare for planning and compliance aspects, in order to achieve your optimal tax position.
Consider buying a property in Sydney? You would better be prepared to pay a 4% duty surcharge. This new tax rule has been put in place on 21st June, 2016 and applicable to all home purchases in New South Wales, making the state the second in Australia to impose stamp duties on foreign purchasers. In addition, there will also be a 0.75% land tax surcharge on top of the aforesaid stamp duty surcharge from 2017 onwards.
In Melbourne of Victoria, the prevailing 3% stamp duty has been increased to 7% since 1st July, 2016. Purchasers from Mainland China have made up bulk of the foreign buying population, and property prices have been doubled in Sydney and risen around 60% in Victoria since 2009. Current property taxes amounted at A$40,490 for an A$1 million property with additional 4.5% surcharge for properties priced above A$1 million.