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The International Tax Handbook The International Tax Handbook 6th Edition The International Tax Handbook 6th Edition The International Tax Handbook 6th Edition Bloomsbury Professional Ltd, Maxwelton House, 41–43 Boltro Road, Haywards Heath, West Sussex, RH16 1BJ © 2017 Nexia International Limited. All rights reserved. The trade marks NEXIA INTERNATIONAL, NEXIA and the NEXIA logo are owned by Nexia International Limited. All rights reserved. No part of this publication may be reproduced in any material form (including photocopying or storing it in any medium by electronic means and whether or not transiently or incidentally to some other use of this publication) without the written permission of the copyright owner except in accordance with the provisions of the Copyright, Designs and Patents Act 1988 or under the terms of a licence issued by the Copyright Licensing Agency Ltd, Saffron House, 6–10 Kirby Street, London EC1N 8TS. Applications for the copyright owner’s written permission to reproduce any part of this publication should be addressed to the publisher. Nexia International is a leading worldwide network of independent accounting and consulting fi rms, providing a comprehensive portfolio of audit, accountancy, tax and advisory services. Nexia International does not deliver services in its own name or otherwise. Nexia International and its member fi rms are not part of a worldwide partnership. Member fi rms of Nexia International are independently owned and operated. Nexia International does not accept any responsibility for the commission of any act, or omission to act by, or the liabilities of, any of its members. Each member fi rm within Nexia International is a separate legal entity. Nexia International does not accept liability for any loss arising from any action taken, or omission, on the basis of the content in this publication. Professional advice should be obtained before acting or refraining from acting on the contents of this publication. Any and all intellectual property rights subsisting in this document are, and shall continue to be, owned by (or licensed to) Nexia International Limited. References to Nexia or Nexia International are to Nexia International Limited. Nexia International also refers to the trading name of Nexia International Limited, a company registered in the Isle of Man. Company registration number: 53513C. Registered offi ce: 1st fl oor, Sixty Circular Road, Douglas, Isle of Man, IM1 1SA. Warning: The doing of an unauthorised act in relation to a copyright work may result in both a civil claim for damages and criminal prosecution. A CIP Catalogue record for this book is available from the British Library. ISBN: 978 1 78451 396 2 Printed and bound by CPI Group (UK) Ltd, Croydon, CR0 4YY Contents Introduction vii Glossary ix Countries Angola 1 Honduras 335 Argentina 7 Hong Kong 341 Australia 15 Hungary 347 Austria 23 India 359 Azerbaijan 33 Indonesia 377 Bahrain 41 Iraq 385 Barbados 47 Ireland (Republic of) 391 Belgium 53 Isle of Man 403 Bolivia 63 Israel 409 Brazil 69 Italy 415 Bulgaria 77 Japan 423 Cambodia 89 Jordan 433 Cameroon 99 Kazakhstan 439 Canada 107 Kenya 449 Cayman Islands 115 Korea, Republic of 455 Channel Islands, Guernsey 123 Kuwait 467 Channel Islands, Jersey 129 Lebanon 473 Chile 135 Liechtenstein 483 China (People’s Republic of) 145 Luxembourg 491 Colombia 153 Malaysia 503 Croatia 159 Malta 515 Cyprus 169 Mauritius 527 Czech Republic 179 Mexico 533 Denmark 187 Morocco 539 Dominican Republic 197 Mozambique 549 Ecuador 205 Myanmar 557 Egypt 219 Netherlands (The) 567 El Salvador 227 Nevis 577 Estonia 235 New Zealand 583 Finland 243 Nigeria 595 France 253 Norway 603 French Polynesia 267 Pakistan 615 Georgia 279 Panama 623 Germany 291 Peru 629 Ghana 303 Philippines 637 Gibraltar 309 Poland 647 Greece 317 Portugal 659 Guatemala 329 Puerto Rico 671 v vi The International Tax Handbook Romania 683 Taiwan 819 Russia 695 Tanzania 825 Saudi Arabia 709 Thailand 837 Senegal 715 Tunisia 847 Serbia 721 Turkey 855 Singapore 731 Uganda 863 Slovakia 743 Ukraine 881 Slovenia 757 United Arab Emirates 889 South Africa 767 United Kingdom 901 Spain 779 United States 915 Sri Lanka 791 Uruguay 923 Sweden 799 Venezuela 929 Switzerland 807 Vietnam 937 Introduction This is the sixth edition of the International Tax Handbook that has been produced by Nexia International, Nexia International is a leading worldwide network of independent accounting and consulting fi rms, providing a comprehensive portfolio of audit, accountancy, tax and advisory services. I would like to thank all the contributors for their invaluable assistance. This edition contains more chapters than previous editions of this book and each chapter provides an overview of the tax system in the relevant country and deals with information generally sought by businesses to understand the fi scal regime. This edition continues to include details of the withholding taxes applied to the major cross border transactions based on the double taxation conventions. This book has been prepared in a tabular format to unify the content of each chapter and highlight the core tax aspects for each country. Each section is split into corporate, personal and indirect taxes which should provide the reader with an overview of the tax system in place in a specifi c country. Every effort has been taken to ensure that the information provided in this book is accurate and up to date. However, it is only meant to provide a general overview of the prevailing tax systems and should not be used as a substitute for professional tax advice. Neither the author nor the publishers can accept any responsibility for any loss sustained by any person relying on the information provided in this book and failing to seek appropriate professional advice. Therefore, I would like to stress the importance of obtaining local advice before any action is taken or decision is made. Any queries can be addressed to the local Nexia offi ces directly, using the contact information provided in the Handbook. For a comprehensive list of Nexia International members worldwide, visit the Nexia International “ Locations ” section at www.nexia.com James Wall [email protected] Editor January 2017 Nexia International Tel: + 44 (0) 20 7436 1114 Fax: + 44 (0) 20 7436 1536 E-mail: [email protected] Web: www.nexia.com vii Glossary CGT Capital Gains Tax CT Corporate Tax (tax on income of corporation) IHT Inheritance Tax PE Permanent establishment (PE) is a fi xed place of business, such as a place of management, a branch, an offi ce, a factory, a workshop, an installation or structure for the exploration of natural resources, any place of extraction of natural resources, a building site or construction or installation project, through which the business is carried on. An agent acting on behalf of the company may also constitute a PE if he has and habitually exercises the authority to do business on behalf of the company. SME Small and medium-sized enterprise VAT Value Added Tax ix Angola (Prepared by the Angolan desk of NG Auditoria e Consultoria Lda, NG Auditoria e Consultoria Lda, [email protected]) I MAIN LEGAL FORMS Legal form General partnership (SENC) and Private corporation (SQ) and Characteristics Limited partnership (SEC) Public corporation (SA) Partners/shareholders General partnership ( Sociedade em Private corporation ( Sociedade por ● Number Nome Colectivo ): Quotas ) (SQ): ● Restrictions Minimum number of partners: two Minimum number of quotaholders: Limited partnership ( Sociedade em two Comandita ): Public corporation ( Sociedade Minimum number of partners: two, An ó nima ) (SA): or fi ve if the capital is represented Minimum number of shareholders: by shares fi ve Directors Management is attributed to the ● One or more directors directors, independent of being (independent of being partners quotaholders) ● General meeting (for relevant decisions) ● Board of Directors or a single director in the cases allowed by law, all controlled by an Audit Committee or an Individual Qualifi ed Auditor ( Conselho Fiscal or Fiscal Ú nico ) 1 2 The International Tax Handbook Legal form General partnership (SENC) and Private corporation (SQ) and Characteristics Limited partnership (SEC) Public corporation (SA) Registration Companies have to register at: ● National Private Investment Agency (Ag ê ncia Nacional para o Investimento Privado - ANIP ) in order to obtain the Private Investment Registry Certifi cate (Certifi cado de Registo do Investimento Privado - CRIP ), licence for import of capital. The minimum value for the investment by the ANIP is US $ 1,000,000 (only for foreign investment) ● Registry of Company Names ( Ficheiro Central de Denomina ç õ es Sociais or Guich é Ú nico da Empresa ) ● Commercial Company Register ( Registo Comercial ) ● Tax authorities declaring the start of activity ● Statistical Record (Instituto Nacional de Estat í stica) ● Registration as importer/exporter (Direc ç ã o Nacional do Com é rcio) ● Social security Registration (Instituto Nacional de Seguran ç a Nacional) ● Bank account opening in a company name; ● Deposit of funds for capitalisation of the project where it is a private investment project Minimum capital None SQ: the amount in Kwanzas equivalent to US $ 1,000 SA: the amount in Kwanzas equivalent to US $ 20,000 Liability General partnership: unlimited, Limited subsidiary and joint liability Limited partnership: limited liability or unlimited, subsidiary and joint liability, depending on the type of partner Governance Partners Board of Directors Audit requirements Not mandatory
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