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Puerto Rico offers attractive tax incentives to lure high-net-worth individuals and businesses to the island, fostering local economic growth.
The Puerto Rico Incentives Code of 2019, known as Act 60, provides significant tax advantages for those who qualify as bona fide residents and meet certain economic contribution requirements.
Act 60 consolidates and updates previous tax incentives, including Act 20 and Act 22, targeting a variety of sectors such as individual investors, businesses, manufacturers, international financial entities, and private equity funds.
Act 20 provides tax incentives for companies based in Puerto Rico that export services to other regions.
Benefits include a fixed income tax rate of 4% on eligible export services and a complete tax exemption on dividends from earnings and profits.
Eligible businesses must maintain a bona fide office in Puerto Rico and render services to clients outside the island.
Act 22 offers a 100% tax exemption on dividends, interest, and capital gains for new Puerto Rico residents.
To qualify, individuals must be bona fide residents, meeting criteria such as spending the majority of the year in Puerto Rico, having no tax home outside Puerto Rico, and showing stronger connections to Puerto Rico than any other location.
Additional requirements include an annual $10,000 donation to local nonprofits and purchasing residential property within two years of establishing residency.
Due to the generous nature of these tax breaks, the IRS has increased its enforcement efforts to prevent abuse of Act 60 incentives.
In 2021, the IRS launched a compliance campaign targeting potentially fraudulent claims, focusing on whether individuals and businesses genuinely meet the residency and income sourcing requirements.
Puerto Rico’s tax incentives offer substantial benefits, but they come with strict compliance requirements.
Properly navigating these can avoid IRS scrutiny and potential penalties.
For those considering a move to Puerto Rico, consulting with experienced tax attorneys is crucial to optimize benefits and ensure compliance.
If you have any queries on Puerto Rico and its tax incentives then please get in touch.
The UK has long been a premier destination for internationally mobile individuals due to its stability, legal system, educational opportunities, and cosmopolitan lifestyle.
However, recent policy changes have reshaped the immigration landscape, necessitating careful planning for those considering relocating to the UK.
In February 2022, the UK closed the Tier 1 (Investor) route, significantly impacting high-net-worth migration.
The focus has shifted towards visa categories that require active engagement with UK businesses and often need endorsement from third-party organizations.
On 6 March 2024, the UK Chancellor introduced major tax regime changes affecting UK-resident, non-UK domiciled individuals.
These changes will influence decisions for those already in the UK or considering a move, highlighting the importance of integrated tax and immigration planning to achieve long-term residency or citizenship goals.
Both routes offer accelerated paths to indefinite leave to remain (ILR) after three years, unlike the standard five-year requirement.
Visas are also available for those with a family connection to the UK, including partners of British citizens or permanent residents and individuals with UK ancestry.
This newly launched program allows significant investment in approved Hong Kong assets, leading to residency and potential permanent status after seven years.
Programs in countries like Antigua and Barbuda, Grenada, and St. Kitts and Nevis offer fast-track citizenship through investment, with benefits including visa-free travel to over 145 countries.
For clients considering international relocation, it’s crucial to navigate the complex interplay of immigration laws, tax implications, and family considerations.
With expert guidance from specialized immigration and tax advisors, clients can make informed decisions about their relocation strategies, ensuring compliance and optimizing their relocation outcomes.
If you have any queries about this article on High Net Worth Immigration Options then please get in touch.
The Portugal Golden Residence Permit Program, often referred to as the Portugal Golden Visa Program, offers a compelling five-year residence by investment opportunity for non-EU nationals.
This program allows investors to live, work, and study in Portugal while enjoying visa-free access to the Schengen Area.
With a minimal physical presence requirement averaging just seven days per year, this program not only facilitates ease of living but also paves the way for citizenship eligibility after five years.
The Portuguese Golden Visa is laden with benefits:
Investors can secure their Portuguese Golden Visa through several investment options:
The application process includes:
The first permit is issued for two years due to adjustments made during the Covid-19 pandemic, with subsequent renewals every two years.
The entire process to secure a residence permit through investment typically extends beyond 18 months due to administrative procedures.
The Portugal Golden Residence Permit Program stands out as a highly attractive option for investors seeking not only a European residence but also a straightforward route to citizenship.
With flexible investment options and a lenient residency requirement, the program offers a practical solution for global investors aiming to enjoy the lifestyle and benefits Portugal has to offer.
If you have any queries about Portugal’s Golden Visa, or tax or other matters in Portugal, then please get in touch.
Italy, a country celebrated for its picturesque landscapes, rich history, and vibrant culture, offers more than just a travel destination.
With major cities like Milan, Rome, and Venice, Italy presents a unique opportunity for investors to gain residence in a well-connected EU market.
The Italy Residence by Investment Program provides a gateway to Europe with a variety of investment options tailored to meet different needs, enabling successful applicants to obtain residence rights within three to four months.
The Italian Golden Visa comes with numerous benefits, including:
Applicants can choose from two main investment avenues to qualify for the Italian residence:
– Invest a minimum of EUR 2 million in Italian government bonds.
– Commit at least EUR 500,000 to Italian shares, reduced to EUR 250,000 for innovative start-ups.
– Make a non-refundable donation of EUR 1 million to projects of public interest in Italy, including fields like culture, education, ecology, and more.
Family members such as a spouse, children, and dependent parents can also apply for a visa under the main applicant’s investment without the need for additional funds.
– Ideal for individuals who can demonstrate a stable annual income from foreign sources.
The Italian Golden Visa is initially granted for two years and can be renewed for an additional three years as long as the investment is upheld. The application process generally takes between 90 to 120 days from submission, with the investment required to be made within three months of entering Italy.
For the Investor Visa Program, purchasing or renting residential property in Italy is necessary following approval. Applicants under the Elective Residence Program must also secure residential real estate and prove stable income.
Residency can evolve into permanent residence after five years, provided the investor relocates to Italy. Interestingly, the program does not mandate a minimum physical presence in Italy, offering flexibility for global investors.
Italy’s Residence by Investment Program not only opens the door to a life in one of the world’s most enchanting countries but also offers a strategic foothold in the European Union.
With flexible investment options and a straightforward application process, this program stands out as a premier choice for those looking to invest in Italy and enjoy the myriad benefits it offers.
If you have any queries about this article on Italy’s Golden Visa regime, or Italian tax or other matters in general, then please get in touch.
Obtaining tax residency in Monaco is appealing to many high net worth individuals due to its favorable tax regime.
Famously, Monaco does not levy personal income tax, which makes the process and requirements of obtaining tax residency an important step.
Tax residency in Monaco is officially recognized through the issuance of a tax residence certificate by the Principality’s authorities.
This certificate, known as the “certificat à des fins de formalités fiscales,” serves as proof of residency for fiscal purposes.
To qualify as a tax resident, applicants must meet specific criteria laid out in Sovereign Ordinance No. 8,372 dated November 26, 2020.
The criteria, which are controlled by the Monegasque government, include:
Applicants must hold a valid “carte de séjour,” or administrative residence permit.
Applicants should either:
Applicants need to prove their residence in Monaco by showing ownership, rental agreements, or cohabitation within the last year, supported by utility bills or other approved documents.
Depending on the case, additional documents such as bank statements or electricity bills might be required to further prove the legitimacy of the residency.
Monaco’s tax policy offers multiple benefits for residents:
These policies make Monaco an attractive destination for individuals seeking to optimize their tax liabilities.
For EU and EEA nationals, applying for residency involves submitting a valid identity card or passport, along with the necessary forms provided by the Monegasque government.
For those outside the EU/EEA, other specific requirements may apply.
For many high net worth individuals, tax residency in Monaco is seen as the holy grail. However, other nil personal tax jurisdictions, such as the UAE, also offer a similar light touch.
However, if one is looking to switch one’s tax residency to another place, then this is not a task to be taken lightly. You need to plan and plan early.
The road to becoming a tax exile is peppered with bear traps.
If you have any queries about this article on Tax Residency in Monaco, or tax matters in Monaco more generally, 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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All you need is your local tax knowledge. For more information please see here or get in touch.
A bustling hotel lobby in Lisbon, Portugal, filled with a mix of travelers and locals enjoying the serene atmosphere. The decor features traditional Portuguese tiles and modern furniture, creating a vibrant yet cozy environment.
The scene begins with “Tax Natives,” a poised journalist with a keen eye for detail, sitting across from our “Secret Adviser,” a well-regarded tax consultant known for their expertise in Portuguese tax law. They’re seated at a small, round table adorned with a floral centerpiece.
[smiling, as they take a sip of espresso]: “Thank you for meeting with me today in such a lively setting. Let’s dive right in. Can you explain how an individual becomes taxable in Portugal?”
[leaning back comfortably, gesturing towards the window where a tram zips by]: “Certainly. In Portugal, tax residency hinges on a few key factors. If someone spends more than 183 days, consecutively or otherwise, within Portuguese territory during any 12-month period starting or ending in a fiscal year, they’re considered tax-resident. Also, having a habitual residence here during any part of that period suggests an intention to maintain and use it as such.”
[A waiter momentarily interrupts, offering a plate of pastéis de nata, which both politely decline with a chuckle before continuing the discussion.]
“And what about the types of income that are taxable for these residents?”
[nods, picking up a napkin and doodling a quick chart]: “Taxable income under Portuguese Personal Income Tax, or PIT, includes employment income, business and professional income, capital gains, and more. Each category has its specifics, like capital income from dividends and interests taxed generally at 28%, with certain exceptions.”
[laughs as a child zooms past their table chasing a balloon]: “Seems like navigating tax law here is as challenging as catching that balloon! Now, what about non-residents?”
[smiling at the scene]: “Non-residents are only taxed on their Portuguese-sourced income. This includes employment performed in Portugal or income from Portuguese real estate.”
Tell us about the Non-Habitual Residents regime which applied for certain new migrants to Portugal. It was almost mythical in its status and was a huge success. What has happened to it?
[Laughs] “As mythical as the unicorn! It was good whilst it lasted. However, the NHR regime was terminated effective January 1, 2024. It still applies to taxpayers who were grandfathered in. In other words, those who qualified to apply for the regime in 2023 and became tax residents of Portugal up until December 31, 2024. The NHR status was particularly attractive because it provided beneficial tax treatment for certain types of non-Portuguese income for its users. For example, they might be able to enjoy overseas income in Portugal without any tax.”
“Unicorn indeed! How does Portugal handle capital gains tax?”
“Capital gains are typically taxed at 28%. But if you’re selling shares of entities in offshore jurisdictions, you’re looking at a 35% rate. Interestingly, gains from real estate are taxed on only 50% of the gain at progressive rates.”
[A hotel staff member accidentally knocks over a decorative vase in the background, causing a slight commotion but quickly resolved.]
“And what about other taxes, like on gifts or inheritance?”
“Portugal does not impose a gift tax per se, but stamp duty might apply at a rate of 10%. Inheritance involving assets in Portugal also triggers stamp duty unless exempted by relation, such as between spouses or direct descendants.”
[scribbling notes furiously]: “One final question, what are the peculiarities of non-cash assets taxes?”
“Importing non-cash assets like vehicles incurs various taxes and fees. VAT applies universally, adjusted by the type of goods and the value of transactions.”
[Both stand, signaling the end of the interview.]
[extending a hand]: “Thank you for these insights. I believe our readers will find them extremely valuable.”
[shaking hands]: “It was my pleasure. Always happy to clarify these complex topics.”
If you have any queries about this article on Private Client Tax in Portugal, or tax matters in Portugal more generally, then please get in touch.
If you are a tax adviser – whether from a legal or accountancy background – then we would love to discuss how you can become one of our ranks of Tax Natives. All you need is your local tax knowledge of Portugal and any other regions around the world
! For more information, please see here or get in touch.
In the wake of the remote and hybrid work revolution, San Francisco is taking proactive steps to adapt its tax structure to the changing economic landscape.
The Offices of Treasury and Controller have drafted a proposal aimed at mitigating risks posed by the current tax system.
This initiative, potentially shaping a ballot measure for November 2024, seeks to address the fallout of the shifting work environment on the city’s tax revenue.
The proposed reforms are the culmination of extensive dialogue with community members and stakeholders, reflecting around 30 meetings.
The primary objectives are to tackle the risk of lost tax revenue, streamline the tax compliance process, and alleviate the tax burdens faced by small businesses.
Key features of the proposal include transitioning away from the payroll factor and Commercial Rents Tax, broadening the Gross Receipts Tax structure, reducing taxes and fees for small enterprises, and enhancing the Small Business Exemption.
A critical aspect of these reforms is their focus on enhancing predictability for both the city and taxpayers.
For the city, the reforms aim to simplify the tax system to foster increased voluntary compliance, thereby making revenue projections more reliable.
Taxpayers, on the other hand, would benefit from clearer guidelines for future tax liabilities, supported by the proposal’s insistence on specific criteria for any forthcoming tax reforms.
The reform package also suggests several procedural adjustments to improve the tax system’s administration and taxpayer compliance.
These include consolidating tax schedules, codifying a voluntary disclosure program, and allocating more resources for administrative guidance.
Furthermore, the proposal advocates for a modification in the process of qualifying tax measures for ballot inclusion, proposing to remove the direct placement of tax measures by a minority of the Board of Supervisors or the mayor.
This change would bring San Francisco’s procedure in line with practices observed in other Californian cities.
Should the proposal be adopted, it promises to significantly streamline San Francisco’s business tax framework by consolidating various taxes into a singular tax system and moving away from a combined payroll and sales factor apportionment model.
Although the proposal is designed to be revenue neutral and does not directly reduce the overall tax burden for businesses in San Francisco, it represents a significant step towards simplifying tax compliance and administration.
The initiative has sparked discussions among taxpayers and business groups, who may advocate for further reductions in the overall tax burden in addition to the simplification measures.
As the proposal moves toward potentially becoming a ballot measure, its development and impact will be closely watched by businesses, policymakers, and the wider San Francisco community.
This tax reform effort underscores San Francisco’s commitment to adapting its economic policies to reflect the evolving nature of work and maintain its status as a vibrant hub for businesses and professionals.
If you have any queries on this article, or US tax matters in general, then please get in touch.
On 7 December 2023, Malta’s Finance Minister announced the implementation of the Nomad Residence Permits (Income Tax) Rules 2023.
These rules offer a beneficial tax regime for digital nomads, reducing their tax burden and simplifying compliance.
Individuals with a valid nomad residence permit will be taxed at a flat rate of 10% on income derived from “authorised work”.
This is a notable decrease from Malta’s progressive tax rate, which can go up to 35%.
“Authorised work” refers to services provided remotely through telecommunications technology by a main applicant either employed by a non-resident employer or self-employed for clients not residing or operating in Malta.
Eligible individuals can benefit from double taxation relief as per Malta’s tax treaties, provided they meet the criteria of being a tax resident in one of the contracting states.
A 12-month exemption period from income tax on authorised work is available, starting either from the issuance of the nomad residence permit or 1 January 2024, whichever is later.
This exemption aims to ease the transition for new permit holders.
To qualify for the exemption, applicants must declare that their residence in Malta during this period is not merely temporary.
However, the exemption does not apply to those whose nomad visa has expired within two years, although they can still benefit from the reduced tax rate.
Income not derived from authorised work will be subject to Malta’s general taxation rules under the Income Tax Act.
Nomad visa applicants must file income tax returns and register for income tax in Malta.
During the first twelve months, income from authorised work is exempt from reporting unless a specific declaration is made.
Proof of foreign tax payment at a rate of at least 10% exempts applicants from reporting that income in Malta, with the responsibility of forwarding proof lying with the Residency Malta Agency.
These new rules make Malta an attractive destination for digital nomads.
The reduced tax rate, combined with the initial tax-exempt period, provides significant financial benefits.
Additionally, the clear definitions and simplified reporting obligations facilitate compliance and reduce administrative burdens for digital nomads.
The approach acknowledges the growing trend of remote working and positions Malta as a forward-thinking jurisdiction that caters to the needs of this emerging workforce segment.
It offers a viable option for digital nomads seeking a tax-efficient base while maintaining compliance with international tax norms.
In summary, Malta’s new tax rules for digital nomads offer an enticing mix of reduced tax rates and simplified procedures, likely to attract more remote workers to its shores.
If you have any comments or queries about this article on the new tax rules for digital nomads in Malta, or other Malta tax matters, then please get in touch.