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Argentina has recently made a significant move by cutting its withholding taxes on international investments.
This decision is part of the country’s broader strategy to attract more foreign investment during challenging economic times.
By lowering the taxes that foreign investors have to pay, Argentina hopes to make itself a more attractive place to do business.
In this article, we’ll explore what withholding taxes are, why Argentina is cutting them, and what this could mean for businesses and investors.
Withholding taxes are taxes that are deducted from payments made to foreign investors.
When an investor from another country earns income in Argentina—whether it’s through interest, dividends, or capital gains—the Argentine government takes a percentage of that income in the form of withholding tax.
These taxes are a way for governments to ensure that they collect revenue from foreign investors, even if those investors don’t live in the country.
The amount of withholding tax varies from country to country, and different types of income (such as dividends or interest) may be taxed at different rates.
Argentina is going through a period of economic uncertainty, with high inflation and challenges in the local economy.
To help boost the economy, the government has decided to reduce the amount of tax it collects from foreign investors.
By cutting withholding taxes, Argentina hopes to make itself more attractive to international businesses and investors.
The idea is that by lowering the tax burden on foreign investors, more companies and individuals will be willing to invest their money in Argentina.
This, in turn, could help stimulate economic growth and create new jobs.
Argentina hasn’t announced the exact percentage for the tax cuts yet, but it is expected to be a significant reduction.
The goal is to bring the country’s tax rates more in line with other countries in the region that have lower withholding taxes, such as Chile and Uruguay.
This would make Argentina more competitive as a destination for international investment.
For investors, this is good news. Lower withholding taxes mean that foreign investors will get to keep more of the money they earn in Argentina.
This could make investing in Argentine businesses more appealing, particularly in sectors like agriculture, energy, and manufacturing.
However, it’s important to note that Argentina’s economy is still facing significant challenges.
While lower taxes might attract more investment, the overall economic situation is still a concern for many potential investors.
Argentina’s decision to cut withholding taxes is a bold move aimed at boosting foreign investment.
By reducing the amount of tax collected from international investors, the government hopes to attract more businesses and individuals to invest in the country.
While the success of this strategy remains to be seen, it might be a step in the right direction for Argentina’s economy.
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Germany is known for having one of the most robust economies in Europe, but it also has a reputation for relatively high corporate taxes.
To remain competitive and attract more international investment, Germany has proposed new corporate tax reforms.
These reforms are designed to lower the tax burden on businesses, promote innovation, and make the country more attractive to foreign investors.
Germany’s new corporate tax proposals are aimed at both large and small businesses. Here are the key changes:
Germany is already a top destination for foreign investment, but the country wants to remain competitive as other nations cut their corporate tax rates.
For example, the United States and the United Kingdom have both taken steps to lower corporate taxes to attract more business.
By lowering its tax rates and offering incentives for innovation, Germany hopes to encourage multinational companies to invest in the country.
This will create more jobs, improve the country’s technological capabilities, and boost the economy overall.
While the tax cuts are popular with many businesses, there has been some criticism of the proposals.
Critics argue that lowering corporate taxes could lead to a reduction in government revenue, which may impact public services like healthcare and education.
Additionally, there are concerns about whether the tax cuts will disproportionately benefit large corporations while smaller businesses may not see as much of a reduction in their tax bills.
Germany’s new corporate tax proposals are part of a broader strategy to make the country more competitive in a global market.
By lowering the corporate tax rate, offering more incentives for R&D, and simplifying tax compliance, the German government hopes to attract more foreign investment and boost the country’s economy.
For foreign investors and multinational companies, these changes represent an exciting opportunity to invest in a country known for its economic stability and innovation. However, businesses should stay informed as the specific details of the reforms are finalised.
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As the 2024 general election approaches, tax policy has become a key issue that voters and lawmakers are closely watching.
With both major presidential candidates offering distinct proposals and control of Congress up for grabs, the outcome of the election will have significant ramifications for the future of tax legislation in the United States.
This pre-election analysis delves into the key tax policy proposals from former President Donald Trump and Vice President Kamala Harris, and what we might expect from key congressional leaders on tax policy in the 119th Congress.
The Tax Cuts and Jobs Act (TCJA) of 2017 brought substantial changes to the US tax code, but many of its provisions are set to expire at the end of 2025.
These expiring provisions include tax cuts for individuals, lower tax rates, and an expanded child tax credit.
For businesses, changes will affect the expensing of investments and the 20% deduction for certain business income, although the 21% flat corporate tax rate will remain in place.
If Congress does not extend or make these provisions permanent, taxpayers could face higher rates and reduced benefits.
The direction of these discussions will largely depend on the outcome of the November election, with potential scenarios ranging from extending the TCJA’s provisions to completely reversing them.
Vice President Kamala Harris has made tax policy a central theme of her campaign. Building on the Biden-Harris administration’s work, particularly the Inflation Reduction Act (IRA) of 2022, Harris is expected to focus on tax credits that promote energy efficiency and green initiatives.
The IRA includes tax credits for clean energy investments, energy-efficient improvements, and electric vehicles.
These incentives are designed to drive innovation and support sustainable economic growth.
Additionally, Harris has proposed significant changes aimed at reducing economic inequality, such as increasing taxes on corporations and high-income earners, expanding the Child Tax Credit, and introducing tax incentives for affordable housing.
Harris’s approach to tax policy is expected to be in line with the Biden administration’s strategies, with some nuanced differences.
She has already outlined plans to raise taxes on those earning over $400,000 annually and to close corporate tax loopholes.
Harris has also proposed using tax incentives to combat climate change and support the construction of affordable housing.
Her administration would likely continue to push for a tax system that supports working families, reduces inequality, and advances sustainability.
During his first term, Donald Trump championed the TCJA, which lowered both individual and corporate tax rates.
In his bid for a second term, Trump has proposed further reducing taxes, particularly for high-income earners and businesses, to stimulate economic growth.
His proposals include extending the tax cuts from the TCJA, lowering the corporate tax rate, eliminating the estate tax, and reversing certain aspects of the Inflation Reduction Act, such as the corporate alternative minimum tax. T
rump’s tax policy priorities focus on reducing tax burdens, fostering investment, and encouraging economic expansion.
If Trump returns to the White House, we can expect an aggressive push to weaken some of the tax provisions introduced under the Biden administration, particularly those related to green energy.
Trump may also seek to leverage the Treasury Department and the IRS to implement changes without needing new legislation, especially if Congress does not support his efforts.
Despite the stark differences in tax policy approaches, there are areas where bipartisan collaboration is possible.
Expanding tax credits like the Child Tax Credit and Earned Income Tax Credit could provide common ground for both parties.
Addressing the expiring provisions of the TCJA might also lead to discussions on extending or modifying these cuts, particularly for middle-income earners.
Additionally, improving infrastructure investment through tax incentives could garner support from both sides of the aisle.
In the current Congress, there have been instances of bipartisan efforts, such as the introduction of the Tax Relief for American Families and Workers Act, which aims to provide tax relief to working families and stimulate economic activity.
Similar initiatives may continue in the 119th Congress, offering opportunities for collaboration on tax policy.
As the 2024 election looms, the future of US tax policy is a critical issue with wide-reaching implications.
The proposals from the presidential candidates and the leadership priorities of key congressional figures highlight a deep divide in approaches but also point to potential areas for bipartisan cooperation.
With key provisions of the TCJA set to expire and ongoing debates about economic fairness and growth, the election outcome will significantly shape the tax policy landscape for years to come.
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On 12 August 2024, the Canadian federal government unveiled several packages of draft legislation aimed at implementing various tax measures, refining previously released draft laws, and introducing technical amendments (collectively referred to as the “August 12 Proposals”).
These proposals build upon the tax measures introduced in the 2024 Federal Budget (Budget 2024) and include updates to earlier draft legislation.
The Canadian government has invited the public to provide feedback on most of these measures by 11 September 2024, with an earlier deadline of 3 September 2024 for comments on the capital gains inclusion rate and lifetime capital gains exemption amendments.
The August 12 Proposals encompass a broad range of tax measures, many of which are discussed in this update. Tax changes related to green economy initiatives will be covered in a separate update.
Budget 2024 proposed increasing the capital gains inclusion rate for corporations and trusts from 50% to 66.67%, with a similar increase for individuals on capital gains exceeding $250,000 in a taxation year, net of certain deductions.
On 11 June 2024, the House of Commons approved a Notice of Ways and Means Motion (NWMM) to amend the Income Tax Act (ITA) and implement this proposed increase.
The August 12 Proposals include revisions to the NWMM amendments, and the Department of Finance has provided explanatory notes for these changes.
The impact of the increased capital gains inclusion rate on the calculation of the capital dividend account (CDA) is also addressed, ensuring that taxpayers have clear guidance during transitional periods.
The CDA is a notional account that tracks the non-taxable portion of capital gains and losses realized by private corporations, allowing for tax-free distributions to Canadian-resident shareholders.
The proposed increase in the capital gains inclusion rate necessitates adjustments to CDA calculations.
For taxation years that straddle the implementation date (25 June 2024), the August 12 Proposals introduce a “blended” inclusion rate to reflect the timing of dispositions within the transitional year.
This blended rate, while necessary for overall tax calculations, created challenges for CDA assessments, as the exact inclusion rate could not be determined until the year-end. The August 12 Proposals resolve this issue by establishing specific rules for calculating CDA during transitional years.
The hybrid surplus rules, which relate to dividends received by Canadian corporations from their foreign affiliates, are also revised.
The August 12 Proposals introduce separate surplus pools for “legacy hybrid surplus” (pre-25 June 2024) and “successor hybrid surplus” (post-24 June 2024).
These distinctions ensure that the treatment of hybrid surplus dividends aligns with the relevant capital gains inclusion rate at the time of the underlying transactions.
Amendments to the Global Minimum Tax Act (GMTA), enacted on 20 June 2024, are included in the August 12 Proposals.
These changes implement the undertaxed profits rule (UTPR), provide transitional safe harbours, and address other elements from the OECD’s latest guidance.
The amendments will apply to fiscal years of qualifying multinational enterprise (MNE) groups beginning on or after 31 December 2024.
The trust reporting requirements are updated to reduce the number of bare trusts affected. The August 12 Proposals introduce new exemptions and modify existing ones, making the rules clearer and less burdensome for taxpayers.
The revised rules will apply to taxation years ending after 30 December 2025, with the Canada Revenue Agency (CRA) having already suspended the 2023 reporting obligations.
The August 12 Proposals address concerns raised about the anti-deferral rules targeting Canadian-controlled private corporations (CCPCs) and their controlled foreign affiliates (CFAs).
The revised measures introduce a carve-out for “foreign accrual business income” (FABI), offering some relief to CCPCs engaged in legitimate business activities abroad.
However, the proposals remain complex and may still impose significant compliance burdens on affected companies.
The excessive interest and financing expenses limitation (EIFEL) rules are amended to include exemptions for certain interest and financing expenses related to regulated energy utilities and purpose-built residential rentals.
These exemptions aim to provide relief to businesses in specific sectors, supporting their continued growth and investment.
The August 12 Proposals also clarify the application of hybrid mismatch rules to foreign affiliates, ensuring that the rules are applied consistently and preventing instances of double taxation on inter-affiliate dividends.
The CEI, introduced in Budget 2024, is further detailed in the August 12 Proposals.
This incentive reduces the capital gains inclusion rate to one-third for qualifying entrepreneurs, with several conditions relaxed compared to the original proposal.
The CEI aims to support business owners by providing substantial tax relief on the sale of their businesses.
The August 12 Proposals represent a comprehensive update to Canada’s tax laws, addressing a range of issues from capital gains to international tax compliance.
While these changes introduce some relief and clarity, they also add layers of complexity, particularly for businesses with international operations.
As the consultation period progresses, further refinements may be made to ensure that the legislation effectively meets its objectives without imposing undue burdens on taxpayers.
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On 17 July 2024, the Luxembourg government unveiled a new bill proposing a range of tax cuts aimed at benefiting both corporations and individuals.
This legislative move aligns with the current government’s commitments for the 2023-2028 period, promising substantial fiscal relief and various other economic benefits.
Starting from the fiscal year 2025, the corporate income tax rate will decrease by one percentage point, bringing it down to 16%.
For income up to €175,000, the reduced rate will be adjusted from 15% to 14%.
This adjustment will see the consolidated corporate tax rate in Luxembourg City (inclusive of the solidarity surcharge and municipal business tax) fall from 24.94% to 23.87%.
Private wealth management companies, known as “société de gestion de patrimoine familiale” (SPF), will see an increase in the minimum annual subscription tax from €100 to €1,000.
Additionally, the determination of the debt portion for the subscription tax base will now be based on the balance sheet at the beginning of the fiscal year rather than January 1st.
Moreover, the government aims to clarify the procedure for withdrawing SPF status in cases of legal non-compliance. Severe breaches can lead to fines up to €250,000 and potential withdrawal of SPF status by the director of the indirect tax authorities (AED) if not remedied within six months. These changes will take effect for breaches occurring after the law’s enactment.
The bill also includes a provision to exempt actively managed exchange-traded undertakings for collective investment in transferable securities (actively managed UCITS – ETF) from the subscription tax.
To bolster Luxembourg’s attractiveness to talent, the government plans to amend the profit-sharing bonus (“prime participative”).
The tax-exempt portion of this bonus will increase from 25% to 30% of annual remuneration, and the total distributable amount will rise from 5% to 7.5% of employer profits.
The tax regime for impatriates will be modernized, introducing a 50% tax exemption on annual gross remuneration up to €400,000, replacing the existing regime that primarily offers tax benefits on certain benefits in kind and impatriation bonuses.
Additionally, a new “young employee bonus” will provide a sliding-scale tax exemption for employees under 30 with annual gross salaries up to €100,000. The bonus, capped at €5,000, will be available only with the first employer and for up to five years.
Starting in fiscal year 2025, the income tax scale will be adjusted to reflect recent inflation and indexed salary increases, significantly reducing the tax burden on individual taxpayers.
Tax credits for single parents will be increased, and a new overtime tax credit (CIHS) will be introduced for employees paid for overtime, excluding civil servants.
This measure aims to resolve tax issues for German cross-border workers who are taxable on overtime earnings in Germany.
Additionally, the maximum allowance for dependent children not living in the household will be raised.
Luxembourg’s proposed tax cuts represent a significant shift in the fiscal landscape, promising substantial benefits for both corporations and individuals.
By reducing corporate income taxes, reforming the tax regime for private wealth management companies, and introducing new tax relief measures for individuals, Luxembourg is positioning itself as an attractive destination for businesses and talent alike.
These changes, aligned with the government’s long-term commitments, are set to take effect from 2025, offering broad-based economic relief and fostering a more competitive and inclusive economic environment.
If you have any further queries about this article on Tax Cuts for Corporations and Individuals in Luxembourg, or other tax issues in Luxembourg, then please get in touch.
On March 12, 2024, the Legislative Assembly of El Salvador passed an amendment to the Income Tax Law (LISR).
This law significantly impacts the taxation of income earned abroad.
Here’s a breakdown of the key changes and their potential effects:
The amendment adds a new provision (IV) to Article 3 of the LISR, specifying that income obtained abroad in any form, including capital movement, remuneration, or emoluments, is not taxable under the law.
Additionally, the amendment exempts income covered under this new provision from the requirement to apply proportionality in determining costs and expenses, as outlined in Article 28 of the LISR.
The reform repeals several existing provisions that currently tax income earned by individuals and entities domiciled in El Salvador from overseas deposits, securities, financial instruments, and derivative contracts.
Overseas profits and returns that were previously taxable will now be considered non-taxable income for taxpayers in El Salvador.
This change is expected to encourage increased capital investment within El Salvador, as investors will no longer face taxation on income generated abroad.
Specifically, the following types of income will be exempt from taxation:
The amendment to El Salvador’s Income Tax Law represents a significant shift in the taxation of income earned abroad by individuals and entities domiciled in the country.
By exempting such income from taxation, the government aims to attract more capital investment into El Salvador.
However, taxpayers should consult with legal and financial advisors to understand the full implications of these changes for their specific circumstances.
If you have any queries about this article on El Salvador’s Income Tax Law, or tax matters in South America more generally, then please get in touch
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In an effort to address economic inequality, the Biden Administration has put forth bold proposals aiming to tax the wealthiest Americans more effectively.
Highlighted in President Biden’s State of the Union Address, these proposals include a minimum tax on the ultra-wealthy, specifically targeting those with assets over $100 million.
This initiative forms part of a broader strategy to generate over $4.5 trillion in new taxes over the next decade, with a significant portion coming from corporations.
The new tax proposals mark a significant shift in how wealth is taxed in the United States.
For the first time, a 25% tax could be imposed not only on annual income but also on the increase in the value of holdings, such as stocks and real estate.
This approach aims to capture the unrealized gains of the ultra-wealthy, a wealth source traditionally elusive to the IRS.
Despite the innovative nature of these proposals, many tax experts (this one included!) express skepticism regarding their enforceability.
Concerns revolve around the IRS’s ability to accurately assess the net worth and complex assets of the ultra-wealthy.
Additionally, the volatility of assets like stocks raises questions about the stability of this revenue source.
Critics argue that simpler changes to the tax code could achieve similar goals without the complexities of estimating unrealised gains.
The Biden Administration’s proposals resonate with global trends toward more equitable taxation.
Following a historic agreement on a minimum tax rate for multinational corporations, international finance ministers have begun discussions on a minimum personal tax for the world’s billionaires.
This reflects a growing consensus on the need for tax systems that more effectively target the wealth of the ultra-rich.
Efforts to increase taxation on the wealthy are not new.
Past administrations, including Obama’s, have sought to implement measures like the “Buffett rule” without success.
Today, despite strong Democratic support for taxing the ultra-wealthy, opposition from Republicans and some centrist Democrats remains a significant barrier.
The ongoing debate reflects a broader conversation about economic equity and the role of taxation in achieving it.
As these tax proposals move through the legislative process, they promise to ignite vigorous debates on fairness, economic policy, and the future of taxation in America.
While the path to implementation may be fraught with challenges, the Biden Administration’s initiative underscores a commitment to addressing wealth inequality and ensuring that all Americans contribute their fair share to the nation’s fiscal health.
Whether these proposals are remotely workable, is a different matter.
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In this article, we consider some of the developments in the off-ing for Kazakhstan slated for 2024.
The dawn of 2024 brings new regulations for the digital mining sector, transitioning from a notification-based system to a structured licensing regime.
This change not only aims to formalize digital mining activities but also introduces specific requirements for digital miners, including the establishment of an automated system for commercial metering of electrical energy and telecommunications systems.
Kazakhstan marks 2024 with the termination of the business inspections moratorium that had been in place since 1 January 2020.
This moratorium, originally designed to shield small and micro-businesses from unscheduled state inspections, is giving way to a new era of regulatory oversight.
The government plans to introduce an innovative automated control system to halve the frequency of on-site inspections, a move articulated by Minister of National Economy Askar Kuantyrov as a significant shift towards minimizing state intervention and reducing penalties for businesses.
With this system, inspections are slated only for entities presenting an elevated risk, as indicated by the system’s assessments.
2024 also welcomes the third stage of the universal revenue declaration, compelling leaders and founders of legal entities, alongside individual entrepreneurs and their spouses, to submit a comprehensive Declaration of Assets and Liabilities.
This progression from the initial stages introduced in 2021 underscores Kazakhstan’s commitment to enhancing transparency and fiscal accountability among its business and public service sectors.
Significant amendments to the laws governing oil, gas, and subsoil use took effect on January 1, 2024.
These amendments seek to modernize the industry’s practices by updating the rules for metering crude oil and gas condensate and introducing a sophisticated information system for the accounting of crude oil, gas condensate, and processing products.
Starting January 1, 2024, Kazakhstan has refined its currency control measures to bolster oversight on foreign exchange transactions.
This includes the introduction of a new procedure for the repatriation of national and/or foreign currency for export or import, aimed at ensuring adherence to regulations and facilitating accurate and compliant foreign exchange activities.
Highlighting Kazakhstan’s dedication to sustainable energy development, the government ratified an agreement with the United Arab Emirates for the implementation of wind power station projects.
This agreement not only symbolizes international cooperation in the fight against global warming but also sets the stage for the development of significant renewable energy projects in Kazakhstan.
The Ministry of Agriculture has implemented reforms to the procedures for selling land plots at electronic auctions, facilitating a more transparent and efficient process.
These reforms include the formation of land plot lists for auctions and the submission of self-prepared proposals for vacant land plots suitable for auction.
These regulatory changes and initiatives represent Kazakhstan’s strategic approach to fostering economic growth, enhancing regulatory compliance, and advancing sustainable development.
As the nation embarks on these new paths, businesses and stakeholders are encouraged to adapt and align with the evolving regulatory landscape to leverage opportunities and navigate potential challenges effectively.
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Portugal, known for its favorable taxation policies on cryptocurrency and its inviting climate, has recently shifted from a period of minimal taxation to introducing more structured tax guidelines in 2023.
This transition emphasizes the importance of understanding the new tax regulations for both residents and potential investors in the digital asset space.
The following tax Categories exist for Crypto Assets:
Crypto assets held for more than 365 days benefit from a tax exemption on any gains realized upon their sale.
Any gains from crypto assets held for less than a year are subject to a 28% capital gains tax. Similarly, income from passive crypto investments, like staking or airdrops, also attracts a 28% tax rate.
For individuals engaged in professional crypto trading, taxation varies.
Factors such as the frequency of trades, use of platforms, and the income’s proportion to other earnings play a critical role in determining tax rates, which can range from 14.5% to 53%.
Confirm your tax residency status and understand the implications of your asset holding periods.
Keep meticulous records of all crypto transactions to ensure accurate tax reporting.
Considering the complexities, seeking advice from tax professionals is recommended for staying compliant and optimizing tax liabilities.
Transactions involving gifts or inheritance of crypto assets are subject to a 10% stamp duty, with commissions attracting a 4% duty.
Portugal now allows real estate purchases directly with cryptocurrencies, following regulatory adjustments in notarial practices. These transactions require adherence to specific compliance measures.
The regulatory landscape for crypto taxation in Portugal is evolving.
Investors and residents should stay informed about the latest changes to ensure compliance and make informed decisions regarding their digital asset investments.
Partnering with a reputable advisory firm can provide valuable guidance and updates on the ever-changing tax environment.
As Portugal continues to refine its approach to crypto taxation, understanding the nuances of the current regulations is crucial for investors and residents alike.
By keeping detailed records, confirming one’s tax residency, and seeking professional advice, individuals can navigate Portugal’s crypto tax maze with confidence, ensuring compliance and optimizing their tax strategy in this dynamic market.
Final thoughts
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In a significant move to adjust its tax framework, the Finance Act 2023 introduced an amendment that impacts non-residents receiving royalty and fees for technical services (FTS) in India.
Since its inception in 1974, the Income Tax Act 1961 has undergone numerous revisions, with the latest changes set to influence multinational corporations and their operations within India.
Previously, the tax rate for royalty and FTS received by non-residents was set at 10% (plus applicable surcharge and cess), as outlined in Section 115A of the Act.
This rate was momentarily increased to 25% in 2013 before being restored to 10% in 2015.
However, the Finance Act 2023 has now doubled this rate to 20% (plus surcharge and cess), effective from 1 April 2023.
The increase in the tax rate to 20% presents a significant shift for non-residents deriving income from royalty and FTS in India.
Given that many tax treaties with countries such as the United Kingdom, Canada, and the United States offer a lower tax rate of 15%, non-residents had previously opted for taxation under Section 115A of the Act due to its beneficial provisions, including specific exemptions from filing tax returns in India under certain conditions.
With the amendment, non-residents are likely to pivot towards claiming benefits under applicable tax treaties, which, while potentially offering lower tax rates, also necessitate additional compliance measures, including tax registrations in India and filing of income tax returns.
The requirement to file tax returns in India, necessitated by claiming treaty benefits, introduces a new layer of compliance for non-residents.
This includes the need for obtaining tax registrations and electronically filing Form 10F, a declaration form used by non-residents to claim treaty benefits.
Although there has been a temporary relief allowing manual submission of Form 10F until 30 September 2023, electronic filing will become mandatory thereafter, adding to the compliance burden for non-residents without a tax registration number.
Moreover, Indian payers making royalty or FTS payments to non-residents must now ensure that they collect and maintain specific documents from the non-residents to apply the treaty rates of withholding tax.
These documents include the Tax Residency Certificate, No Permanent Establishment Declaration, and the electronically filed Form 10F.
Failure to comply with these documentation requirements may result in withholding tax being applied at the higher domestic rate, along with potential penalties for the Indian payer.
The amendment could also have financial implications for Indian payers, especially in cases where royalty or FTS payments are grossed-up to cover the tax liability of the non-resident recipient.
The increased tax rate may lead to higher cash outflows for Indian payers, emphasizing the importance of efficient tax planning and compliance.
The Finance Act 2023’s decision to double the tax rate on royalty and FTS for non-residents marks an important change in India’s tax regime, aiming to align with global taxation practices.
While this may increase the tax burden and compliance requirements for non-residents, leveraging tax treaty benefits could mitigate some of these challenges.
As India continues to refine its tax laws, it is crucial for non-residents and Indian payers alike to stay informed and compliant with the evolving legal landscape.
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