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A Glimpse at Taxation and Investment in Cyprus 2019 WTS Cyprus Cyprus
Cyprus Tax and Investment Facts A Glimpse at Taxation and Investment in Cyprus 2019 WTS Cyprus Cyprus WTS Cyprus was established It is our philosophy to provide in 2009 by professionals with attentive, re sponsive and per- significant experience in their sonalised services. For this pur- fields of expertise to serve pose the firm's management the needs of local and inter- team are closely involved in national clients as a “single all assignments and the firm’s point of contact” in the areas staff are highly committed to of Tax, Financial and Business completing engagements on Consulting services. a timely and efficient basis. Our goal is to be exceptional Our Services: in every way we can. We are → Tax Advisory and Tax committed to providing Compliance Services professional services of the → Financial and Business highest level to our clients, Advisory Services regardless of size or market. → Risk Management and We specialise in providing Assurance Engagements Tax Advisory and Tax → Accounting Compliance services, → Payroll Services Accounting and Business Advisory, as well as Risk Find more on wtmscyprus.co Management and Assurance engagements. Our services Contacts in Cyprus are not just limited to Cyprus- Nicolas Kypreos, Partner oriented matters. We can [email protected] serve clients in various other jurisdictions through our inter- Pambos Chrysanthou, Partner national network of experts, pambos.chrysanthou@ WTS Global. wtscyprus.com WTS Cyprus Ltd. is a member of WTS Global for Cyprus. 2 Tax and Investment Facts 2019 x Cyprus Table of Contents 1 Ways of Doing Business / Legal Forms of Companies 4 2 Corporate Taxation 11 3 Double Taxation Agreements 38 4 Transfer Pricing 39 5 Anti-avoidance Measures 42 6 Taxation of Individuals / Social Security Contributions 47 7 Indirect Taxes 57 8 Inheritance, Gift and Wealth Tax 63 Tax and Investment Facts 2019 x Cyprus 3 1 Ways of Doing Business / Legal Forms of Companies The Republic of Cyprus is a member of the eurozone and a Member State of the European Union. -
2021 Revenue Ordinance
2021 Revenue Ordinance As Proposed on December 5, 2019 ii Revenue Ordinance of 2021 to Levy Taxes and Fees and Raise Revenue For the City of Savannah Georgia As adopted on December 18, 2020 Published by City of Savannah Revenue Department Post Office Box 1228 Savannah, GA 31402-1228 CITY OF SAVANNAH 2021 CITY COUNCIL Mayor Van R. Johnson, II Post 1 At-Large Post 2 At-Large Kesha Gibson-Carter Alicia Miller Blakely District 1 District 2 Bernetta B. Lanier Detric Leggett District 3 District 4 Linda Wilder-Bryan Nick Palumbo District 5 District 6 Dr. Estella Edwards Shabazz Kurtis Purtee Revenue Ordinance Compiled By Revenue Director/City Treasurer Ashley L. Simpson Utility Billing Manager Nicole Brantley Treasury Manager Joel Paulk Business Tax & Alcohol License Manager Judee Jones Revenue Special Projects Coordinator Saja Aures Table of Contents Revenue Ordinance of 2021 ....................................................................................................................... 1 ARTICLE A. GENERAL ............................................................................................................................... 1 Section 1. SCOPE; TAXES AND FEES .................................................................................................... 1 Section 2. DEFINITIONS ........................................................................................................................... 1 Section 3. JANUARY 1 GOVERNS FOR YEAR ...................................................................................... -
Tax Haven Networks and the Role of the Big 4 Accountancy Firms
-RXUQDORI:RUOG%XVLQHVV[[[ [[[[ [[[²[[[ Contents lists available at ScienceDirect Journal of World Business journal homepage: www.elsevier.com/locate/jwb Tax haven networks and the role of the Big 4 accountancy firms Chris Jonesa,⁎, Yama Temouria,c, Alex Cobhamb a Economics & Strategy Group, Aston Business School, Aston University, Birmingham B4 7ET, UK b Tax Justice Network, Oxford, UK c Faculty of Business, University of Wollongong Dubai, UAE ARTICLE INFO ABSTRACT Keywords: This paper investigates the association between the Big 4 accountancy firms and the extent to which multi- Tax havens national enterprises build, manage and maintain their networks of tax haven subsidiaries. We extend inter- Varieties of capitalism nalisation theory and derive a number of hypotheses that are tested using count models on firm-level data. Our Corporate taxation key findings demonstrate that there is a strong correlation and causal link between the size of an MNE’s tax Poisson regression haven network and their use of the Big 4. We therefore argue that public policy related to the role of auditors can Big 4 accountancy firms have a significant impact on the tax avoidance behaviour of MNEs. 1. Introduction 2014 which has provided a number of clear insights. These documents showed that PwC assisted MNEs to obtain at least 548 legal but secret Given the impact that the recent financial crisis of 2008 has had on tax rulings in Luxembourg from 2002 to 2010. The rulings allowed the public finances of developed economies, the use of tax avoidance MNEs to channel hundreds of billions of dollars through Luxembourg, measures by multinational enterprises (MNEs) has come under in- arising from economic activities that took place in other jurisdictions creasing scrutiny from various governments and civil society organi- and with effective tax rates so low that they saved billions of dollars in sations across the world. -
Panama Papers Leaks
GRAY TOLUB1 LLP Focusing on Domestic & International Taxation, Real Estate, Corporate, and Trust & Estate Matters. Client AlertAPRIL 04, 2016 AUTHORS Armin Gray Benjamin Tolub PANAMA PAPERS LEAKS: SUBJECT THE TAX MAN COMETH OVDP Panama On April 03, 2016, the press reported that 11.5 million records were leaked from Panamanian law firm Mossack Fonseca. The records detail offshore holdings of the celebrities, politicians, and the mega-rich many of which were purportedly engaged in illegal activities including tax evasion. Such leaks have been referred to as the “Panama papers” or the “Wikileaks of the mega-rich” by some newspapers.1 More details can be found at the website of the International Consortium of Investigative Journalists (“ICIJ”), which have summarized their findings as follows: The largest cross-border journalism collaboration ever has uncovered a giant leak of documents from Mossack Fonseca, a global law firm based in Panama. The secret files: • Include 11.5 million records, dating back nearly 40 years – making it the largest leak in offshore history. Contains details on more than 214,000 offshore entities connected to people in more than 200 countries and territories. Company owners 1 See Toppo, Greg, “Worldwide, jaws drop to Panama Papers’ Leak”, USA Today, last accessed April 3, 2016, available at: http://www.usatoday.com/story/news/2016/04/03/reactions- panama-papers-leak-go-global/82589874/. www.graytolub.com Client Alert Page 2 in [sic] billionaires, sports stars, drug smugglers and fraudsters. • Reveal the offshore holdings 140 politicians and public officials around the world – including 12 current and former world leaders. -
The Government of the Hungarian People's Republic
CONVENTION BETWEEN THE GOVERNMENT OF THE HUNGARIAN PEOPLE'S REPUBLIC AND THE GOVERNMENT OF THE ITALIAN REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND CAPITAL AND THE PREVENTION OF FISCAL EVASION.1 The Government of the Hungarian People's Republic and the Government of the Italian Republic, desiring to promote and facilitate the economic relations between the two countries, have agreed to conclude a Convention for the avoidance of double taxation with respect to taxes on income and capital and the prevention of fiscal evasion of which the provisions are the following: Article 1 - Personal scope This Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2 - Taxes covered 1. This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State or its political or administrative subdivisions or local authorities, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income and on capital taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation. 3. The existing taxes to which this Convention shall apply are the following: (a) in the case of the Italian Republic: (1) the individual income tax (imposta sul reddito delle persone fisiche); (2) the tax on the income of legal entities (imposta sul reddito delle persone giuridiche); and (3) the local income tax (imposta locale sui redditi), even if withheld at the source (hereinafter referred to as "Italian tax"); (b) in the case of the Hungarian People's Republic: (1) the income taxes (j”vedelemad¢k); (2) the profit taxes (nyeres‚gad¢k); (3) the enterprises' special tax (v llalati kl”nad¢); (4) the tax on buildings (h zad¢); 1 Date of Conclusion: 16 May 1977. -
The Notion of Tax and the Elimination of International Double Taxation Or Double Non-Taxation”
IFA 2016 MADRID CONGRESS “The notion of tax and the elimination of international double taxation or double non-taxation” Luxembourg national report Branch reporters: Chiara Bardini*, Sandra Fernandes** Summary and conclusions The concept of tax under Luxembourg domestic law is based on the basic distinction between compulsory levies that qualify as taxes (“impôts”) and other compulsory levies, such as fees (“taxes”). In general, the term tax can be defined as a compulsory monetary levy imposed by public authorities on the taxpayers in order to mainly raise revenue for which nothing is received in return. In Luxembourg, taxes can only be raised by the Luxembourg State and the municipalities in accordance with the principles of legality, equality and annuality. The Luxembourg tax system relies on the basic distinction between direct and indirect taxes. The Luxembourg direct taxes are levied on items of income and of capital. The main Luxembourg income taxes are the individual income tax, the corporate income tax and the municipal business tax. The net wealth tax, the real estate tax and the subscription tax are the most important Luxembourg taxes levied on items of capital. The Luxembourg notion of “tax” is crucial for the purpose of granting the domestic unilateral foreign tax credit, of applying the domestic participation exemption regime. As a rule, a foreign levy only qualifies for the purpose of such domestic provisions provided that such foreign levy is an income tax and that its main features are comparable to the Luxembourg income tax (i.e. a national income tax imposed on a similar taxable base. -
Optimal Benefit-Based Corporate Income
Optimal Benefit-Based Corporate Income Tax Simon M Naitram∗ Adam Smith Business School, University of Glasgow June 26, 2019 Abstract I derive an optimal benefit-based corporate tax rate formula as a function of the public input elasticity of profits and the (net of) tax elasticity of profits. I argue that the existence of the corporate income tax should be justified by the benefit-based view of taxation: firms should pay tax according to the benefits they receive from the use of the public input. I argue that benefit-based corporate taxation is normatively fair. Since the public input is a location-specific factor, a positive benefit-based corporate tax rate is also feasible even in a small open economy. The benefit-based view gives three clear principles of corporate tax design. First, we should tax corporate profits at source. Second, the optimal tax base is location-specific rents. Third, profit shifting is normatively wrong. An empirical application of the formula suggests the optimal benefit-based corporate tax rate on public corporations in the United States lies in the range of 35 to 52 percent. JEL: H21; H25; H32; H41 Keywords: benefit principle; optimal corporate tax; public input 1 Introduction The view that `corporations must pay their fair share' dominates public opinion. In 2017, Amer- icans' biggest complaint about the federal tax system was the feeling that some corporations do not pay their fair share of tax. Sixty-two percent of respondents said they were bothered `a lot' by corporations who did not pay their fair share (Pew Research Center, 2017a). -
Tax Heavens: Methods and Tactics for Corporate Profit Shifting
Tax Heavens: Methods and Tactics for Corporate Profit Shifting By Mark Holtzblatt, Eva K. Jermakowicz and Barry J. Epstein MARK HOLTZBLATT, Ph.D., CPA, is an Associate Professor of Accounting at Cleveland State University in the Monte Ahuja College of Business, teaching In- ternational Accounting and Taxation at the graduate and undergraduate levels. axes paid to governments are among the most significant costs incurred by businesses and individuals. Tax planning evaluates various tax strategies in Torder to determine how to conduct business (and personal transactions) in ways that will reduce or eliminate taxes paid to various governments, with the objective, in the case of multinational corporations, of minimizing the aggregate of taxes paid worldwide. Well-managed entities appropriately attempt to minimize the taxes they pay while making sure they are in full compliance with applicable tax laws. This process—the legitimate lessening of income tax expense—is often EVA K. JERMAKOWICZ, Ph.D., CPA, is a referred to as tax avoidance, thus distinguishing it from tax evasion, which is illegal. Professor of Accounting and Chair of the Although to some listeners’ ears the term tax avoidance may sound pejorative, Accounting Department at Tennessee the practice is fully consistent with the valid, even paramount, goal of financial State University. management, which is to maximize returns to businesses’ ownership interests. Indeed, to do otherwise would represent nonfeasance in office by corporate managers and board members. Multinational corporations make several important decisions in which taxation is a very important factor, such as where to locate a foreign operation, what legal form the operations should assume and how the operations are to be financed. -
Relationship Between Tax and Price and Global Evidence
Relationship between tax and price and global evidence Introduction Taxes on tobacco products are often a significant component of the prices paid by consumers of these products, adding over and above the production and distribution costs and the profits made by those engaged in tobacco product manufacturing and distribution. The relationship between tax and price is complex. Even though tax increase is meant to raise the price of the product, it may not necessarily be fully passed into price increase due to interference by the industry driven by their profit motive. The industry is able to control the price to certain extent by maneuvering the producer price and also the trade margin through transfer pricing. This presentation is devoted to the structure of taxes on tobacco products, in particular of excise taxes. Outline Tax as a component of retail price Types of taxes—excise tax, import duty, VAT, other taxes Basic structures of tobacco excise taxes Types of tobacco excise systems Tax base under ad valorem excise tax system Comparison of ad valorem and specific excise regimes Uniform and tiered excise tax rates Tax as a component of retail price Domestic product Imported product VAT VAT Import duty Total tax Total tax Excise tax Excise tax Wholesale price Retail Retail price Retail & retail margin Wholesale Producer Producer & retail margin Industry profit Importer's profit price CIF value Cost of production Excise tax, import duty, VAT and other taxes as % of retail price of the most sold cigarettes brand, 2012 Total tax -
Gunpowder Empires
Gunpowder Empires James Gelvin “Modern Middle East” Part 1 - Chapter 2 expanded lecture notes by Denis Bašić Gunpowder Empires • These empires established strong centralized control through employing the military potential of gunpowder (naval and land-based siege cannons were particularly important). • The major states of the Western Hemisphere were destroyed by European gunpowder empires while throughout the Eastern Hemisphere, regional empires developed on the basis of military power and new centralized administrations. • The world gunpowder empires were : the Ottoman, Safavid, Moghul, Habsburg, Russian, Chinese, and Japanese. • Emperor vs. King Military Patronage State • brought to the Middle East by Turkic and Mongolian rulers • Their three main characteristics are : • they were essentially military • all economic resources belonged to the chief military family or families • their laws combined dynastic laws, local laws, and Islamic law (shari’a) Ottoman Empire - 1st Islamic gunpowder empire • The Ottoman Empire was the first of the three Islamic empires to harness gunpowder. • Most probably the Ottomans learned of gunpowder weapons from renegade Christians and used it to devastating effects in the Battle of Kosovo in 1389. • The Ottomans used the largest cannons of the time to destroy the walls and conquer Constantinople in 1453. They conquered Constantinople the same year when the Hundred Years’ (116-year) War in Europe ended. The Siege of Constantinople (painted 1499) Sultan Mehmed II (1432-1481) on the road to the siege of Constantinople painter : Fausto Zonaro (1854-1929) The Great Ottoman Bombard Prior to the siege of Constantinople it is known that the Ottomans held the ability to cast medium-sized cannon, yet nothing near the range of some pieces they were able to put to field. -
Introduction
Most Litigated Legislative Most Serious Appendices Case Advocacy Issues Recommendations Problems Introduction to International Issues: Compliance Challenges Increase International Taxpayers’ Need for IRS Services and May Undermine the Effectiveness of IRS Enforcement Initiatives in the International Arena Introduction to International Issues: Compliance Challenges Increase International Taxpayers’ Need for IRS Services and May Introduction Undermine the Effectiveness of IRS Enforcement Initiatives in the International Arena WHY ADDRESS TAX ISSUES FACING INTERNATIONAL TAXPAYERS? In recent years, globalization has pushed an increasing number of taxpayers (including small- and medium-sized businesses and individuals) to seek economic opportunities abroad.1 It also has increased competition among tax administration agencies for tax bases and sources of revenue. The revenue generated depends on governments’ administrative capacities to collect taxes, and more importantly, on taxpayers’ willingness and ability to comply. For this reason, 40 economies made it easier to pay taxes last year.2 In contrast, a recent World Bank report ranks the United States 66th in time spent to comply and 62nd in the ease of paying taxes among 183 countries surveyed.3 International taxpayers who are subject to complex U.S. tax rules and reporting require ments can be grouped into four categories: ■■ U.S. individuals working, living, or doing business abroad; ■■ U.S. entities doing business abroad; ■■ Foreign individuals working or doing business in the U.S.; and ■■ Foreign entities doing business in the U.S.4 The complexity of international tax law, combined with the administrative burden placed on these taxpayers, creates an environment where taxpayers who are trying their best to comply simply cannot. -
The Financial Secrecy Index: Shedding New Light on the Geography of Secrecy
The Financial Secrecy Index: Shedding New Light on the Geography of Secrecy Alex Cobham, Petr Janský, and Markus Meinzer Abstract Both academic research and public policy debate around tax havens and offshore finance typically suffer from a lack of definitional consistency. Unsurprisingly then, there is little agreement about which jurisdictions ought to be considered as tax havens—or which policy measures would result in their not being so considered. In this article we explore and make operational an alternative concept, that of a secrecy jurisdiction and present the findings of the resulting Financial Secrecy Index (FSI). The FSI ranks countries and jurisdictions according to their contribution to opacity in global financial flows, revealing a quite different geography of financial secrecy from the image of small island tax havens that may still dominate popular perceptions and some of the literature on offshore finance. Some major (secrecy-supplying) economies now come into focus. Instead of a binary division between tax havens and others, the results show a secrecy spectrum, on which all jurisdictions can be situated, and that adjustment lfor the scale of business is necessary in order to compare impact propensity. This approach has the potential to support more precise and granular research findings and policy recommendations. JEL Codes: F36, F65 Working Paper 404 www.cgdev.org May 2015 The Financial Secrecy Index: Shedding New Light on the Geography of Secrecy Alex Cobham Tax Justice Network Petr Janský Institute of Economic Studies, Faculty of Social Sciences, Charles University in Prague Markus Meinzer Tax Justice Network A version of this paper is published in Economic Geography (July 2015).