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The Antigua and Barbuda Citizenship by Investment Program offers a pathway to citizenship for high-net-worth individuals and their families, providing access to the European and Caribbean markets and key Asian financial centers.
Holders of an Antigua and Barbuda passport enjoy visa-free or visa-on-arrival access to over 150 destinations, including major hubs like Hong Kong, Singapore, the UK, and Europe’s Schengen Area.
The program allows the inclusion of a spouse, dependent children under 31, parents and grandparents over 55, and unmarried siblings of any age of the main applicant or their spouse. Dependents can also be added post-citizenship grant. Commonwealth Membership
Citizenship includes privileges in the UK and other Commonwealth countries.
The nation offers excellent air links and is an appealing location for residence or owning a second home.
To qualify, applicants must choose from one of the following:
The minimum investment required will rise to USD 200,000 by June 30, 2024. This provides a limited window under current, more favorable investment conditions.
This program not only facilitates global travel and business opportunities but also requires minimal physical presence, making it an attractive option for investors seeking flexible citizenship solutions.
If you have any queries about the Antigua and Barbuda Citizenship by Investment Program then please get in touch
The scene is set in a bustling hotel lobby in Mumbai. The crowd is excited as it is just hours before Mumbai Indians crucial game in the Indian Premier League (“IPL”).
The interviewer, Our Chief Tax Native, and the interviewee, Secret Adviser in India, are seated on a comfortable sofa, sipping coffee.
There’s a background hum of activity—guests checking in, a receptionist arguing with a new guest, and a cleaner fussing over something nearby. Secret Adviser seems relaxed, while Tax Natives appears focused on their questions.
[Leaning forward with a notepad in hand]
Good morning, Secret Adviser. Let’s talk about taxes in India. What are the basic principles of taxation there?
[Sips coffee]
Good morning, Tax Natives. In India, the Income-tax Act, 1961, governs personal taxation. Generally, Indian residents are taxed on their worldwide income, while non-residents are taxed only on income that originates in India.
[Frustratingly shakes their pen] I see. So, how is a person’s residential status determined for tax purposes?
[Leans back, relaxing]
It depends on their physical presence in India. You’re considered a resident if you’re in India for at least 182 days during a financial year, or 60 days during a financial year and 365 days in the previous four years.
But there are exceptions, especially for those who leave India for work or visit India from abroad.
Now, what’s this about the new income tax regime in India? I heard it’s quite different from the old one.
[Nods] Yes, it’s a major shift. The new regime offers lower tax rates if you give up certain tax deductions and exemptions.
From April 2023, it’s the default regime, but taxpayers can choose the older one if they prefer.
It’s aimed at simplifying the tax structure and is particularly beneficial for high-net-worth individuals due to lower surcharge rates.
[Meanwhile, the receptionist is in a heated argument with a new guest about a booking mix-up.]
Busy morning here! Let’s talk about the recent changes in tax rates. I heard there’s a reduction in the surcharge for the super-rich?
Yes, from April 2023, the surcharge rate was reduced from 37% to 25% for those earning over 50 million rupees.
This has lowered the effective tax rate from 42.74% to 39%, which is significant for high-income individuals.
[Writes down notes…or makes a doodle]
That’s quite a relief for them. What about capital gains? Any new changes there?
[Nods]
There’s a cap on the exemption for long-term capital gains from the sale of residential property. If the gains exceed 100 million rupees, they are now taxable. This cap was introduced from April 2023 to prevent excessive tax breaks.
[The tourist returns, holding a map upside down, clearly still lost. Tax Natives and Secret Adviser point him in the right direction, and he leaves with a smile.]
[Smiling] He’ll get there eventually. Now, what about gift and succession taxes? Are those coming back?
[Shakes her head]
Not quite. India doesn’t have succession or inheritance tax, and gift tax was abolished in 1998.
However, there’s a deemed gift tax in the income tax regime. It applies to money or property received without consideration or at an undervalue.
Recent amendments made it clear that gifts received by non-residents or RNOR from Indian residents are taxable in India.
[The receptionist’s argument with the guest reaches a resolution, and there’s a round of applause from the lobby staff.]
[Grinning] Looks like things are calming down. One last question: how does India deal with cross-border structuring and regulatory issues for HNIs?
[Leans in] India has an extensive network of tax treaties with various jurisdictions. There’s also the Black Money Act, which addresses undisclosed foreign income and assets.
It’s been a big tool in tackling tax evasion, granting authorities wide-ranging powers to investigate.
In terms of entrepreneurs and private trusts, the abolition of the dividend distribution tax in 2020 changed things, and the ‘angel tax’ now applies to share premiums exceeding fair market value, even for non-residents.
[Nods] Thanks for the detailed explanation, Secret Adviser. Enjoy your coffee, and watch out for that tourist!
[Laughs] Thanks, Tax Natives. I’ll keep my eyes peeled!
If you have any queries about this article on private client tax in India, or Indian tax matters more generally, then please get in touch.
In a time of increasing financial strain due to the European Central Bank’s (ECB) continuous interest rate hikes, families are feeling the pinch.
So many people will be turning to that even more esteemed bank. The Bank of Mum and Dad!
In some scenarios, this doesn’t just mean cash hand outs. It might also mean gifting properties to children (or indeed other family members).
But how can property be gifted in Spain without attracting high taxes?
Are you thinking of gifting your Spanish property but don’t want to be faced with high taxes? Let our expert advisors help you transfer your family property in the most tax-efficient way, avoiding unnecessary costs all the way. Reach out now!
Gifting property in Spain is becoming a popular way for parents, spouses, and family members to support their loved ones without incurring excessive taxes.
This practice has gained traction as several regions in Spain, including Andalucia, Madrid, and Galicia, have implemented tax laws that significantly reduce or eliminate inheritance and gift taxes.
Gifting property or money occurs in various scenarios:
The Donor and the donee should be aware of the potential tax liabilities involved:
This tax applies if the property’s value has increased since you acquired it.
The capital gain is calculated by subtracting the purchase price and related costs from the property’s value at the time of gifting.
You will be taxed on this gain at a rate of 19% (or 24% if you’re a non-resident donor from outside the EU).
This is a local tax levied by the municipality on the increase in the land value of the property since it was last acquired.
The rate and rules for calculating Plusvalía Tax can vary depending on the specific location of the property.
Spain has a national gift tax, but rates are set by individual regions (Autonomous Communities).
In some regions, there can be significant exemptions for gifts to close relatives, such as children or spouses.
For instance, some regions offer a nearly zero tax rate for gifts between parents and children.
It’s important to research the specific tax rates that apply in the region where the property is located.
Worried about capital gains or gift taxes when transferring your property? Our network of experts can help keep your liabilities low across regional tax rules. Get in touch now to protect your assets and guarantee a smooth transfer process!
Besides taxes, there are additional expenses to consider, including lawyer’s fees, notary fees, and land registry fees.
To ensure a smooth and tax-efficient transfer, it’s crucial to retain a lawyer from the beginning. The gift deed must be prepared and witnessed by a Spanish notary.
Proper planning is essential, as failing to follow the correct legal procedures can lead to a significant tax burden.
For joint property owners seeking to re-arrange their holdings, a DJPO can be an effective alternative, reducing taxes by up to 86%.
It applies in situations like divorce, re-arranging inheritances, and property re-organization among family and friends.
Gifting property can be an excellent way to help loved ones while minimizing tax obligations.
To avoid high taxes and ensure a smooth legal process we would certainly recommend tapping into local expertise
Ready to gift those closest to you with your Spain property? Make sure they’re not left with a big tax bill when you do. Reach out now to connect with an expert Spain tax advisor and start the gifting process with confidence.
The enactment of the Finance Act 2024 marks a significant overhaul of the UK’s pensions tax framework, particularly with the abolition of the Lifetime Allowance (LTA).
This adjustment, initially announced in the Spring 2023 Budget, removes a cap that has governed tax-efficient pension savings since 2006.
The key changes can be summarised as follows:
The LTA, a cornerstone of pension savings taxation, has been dismantled, removing the upper limit on tax-efficient pension savings.
To replace the LTA, two new allowances have been introduced:
Caps tax-free pension commencement lump sums (PCLS) or the tax-free portion of un-crystallised funds pension lump sums (UFPLS).
Sets the combined lifetime and death benefits cap.
For the 2024/25 tax year, the LSA is set at £268,275, and the LSDBA is £1,073,100.
This new provision allows for further lump sum payments beyond the LSA limits, subject to marginal-rate income tax.
Caps tax-free overseas transfers, aligning with an individual’s LSDBA at £1,073,100 for the 2024/25 tax year.
The obligation for scheme administrators to report LTA-related events to HMRC has been replaced with a requirement to report payments exceeding the LSA/LSDBA limits.
Members receiving a PCLS must now receive “Relevant Benefit Crystallisation Event (RBCE) statements,” detailing the remaining mounts of their LSA and LSDBA.
In light of these substantial changes, trustees of occupational pension schemes should consider two primary actions:
Trustees should ensure administrators are prepared for the incoming changes, including the incorporation of new lump sum allowances in retirement planning and compliance with reporting requirements.
Additionally, trustees should verify that any ongoing buy-out transactions with insurers consider the updated framework.
Trustees may need to amend scheme rules to accommodate the ability to pay PCELS, remove outdated references to the LTA, and potentially adjust benefit accrual limits. While an overriding amendment in the Finance Act 2024 provides temporary relief, proactive adjustments may simplify scheme governance in the long run.
The Finance Act 2024 represents a shift in the taxation of pension savings in the UK.
By abolishing the Lifetime Allowance and introducing new allowances and reporting requirements, the Act aims to simplify the pensions tax landscape.
Of course, it hasn’t done any such thing!
If you have any queries about this article on changes to the lifetime allowance, or other UK tax matters, then please 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.
Spring Budget 2024 delivered a shock to the system. Facing a ruinous election, it is almost as if the Tories were left with one option to steal Labour’s thunder and abolish the non-dom regime themselves.
I am sure they enjoyed themselves in the commons bar afterwards.
However, as the Bard once said, “these sudden joys have sudden endings. They burn up in victory like fire and gunpowder.”
Will the proposals supercharge the UK economy – or do they simply look like the actions of economic arsonists?
Regardless, recent missives from the Labour Party indicate a commitment to not only retain the Government’s proposal, but to further fortify them.
Removing the few silver linings in those original proposals.
New arrivals to the UK who qualify for the new regime will benefit from a full exemption on foreign income and gains for the first four years that they are resident for tax purposes.
In contrast to the current remittance basis, those foreign income and gains (“FIG”) can be brought to the UK without penalty at any time (as long as they arose in the four year window).
After the four year window has closed, they will be taxed like any UK resident and domiciled taxpayer.
The new regime will potentially apply to:
New arrivals must have had a continuous absence from the UK for a period of ten years.
Those who are already in the UK may benefit as well, although the window may be much narrower. This is because they will need to have been tax resident for fewer than four tax years from 6 April 2025. They can benefit until their four years are up.
The above is relatively straightforward. The issues will arise when it comes to dealing with those who have been in the UK for much longer and might also have established trusts and other entities reflecting their status.
We are told that there will be the following transitional rules:
We were told that all new foreign income and gains that arise within a trust from 6 April 2025 will be taxable.
However, where such income and gains arose in such a trust before 6 April 2025, then it will not be taxed unless:
The main connecting factor that determines a person’s exposure to IHT is domicile. So, if we are digging a hole and burying the concept for tax purposes, what is to be done here?
Under vaguer proposed rules, a new test such that a person would only be subject to IHT once they had been resident in the UK for 10 years. On the other hand, exposure to IHT would only be lost when the person had been resident outside the UK for a further 10 years.
It will be interesting to see if those who have remained domiciled in UK domiciliary can escape the scope of IHT on worldwide assets 10 years after leaving the UK, but it appears this may be the case based on the information available so far. If so, this could be seen as a major ‘sweetener’ for expats.
However, notably, we were told that the treatment of non-UK assets settled into a trust by a non-UK domiciled settlor prior to April 2025 would not change and remain excluded property (subject to existing exceptions).
Following the release of a document from Labour’s PR team, and oddly not to be located on their website, they have now formally set out their own proposals.
Labour asserts that its plans on IHT will raise an extra £430m each year in extra IHT. However, the evidence for such claims is pretty shaky.
The Tories proposals seemed like shot in the arm – for all those other jurisdictions looking to attract global wealth, anyway.
The fact that Labour wants to push the envelope even further might be politically bold – but might look like economic self-sabotage.
As Billy boy said, “All the world’s a stage, and all the men and women merely players. They have their exits and their entrances.
The question here is will there be more exits or entrances?
Let’s hope there is no Shakespearean tragedy.
If you have any queries about this article on Labour’s Further Changes to Non-Dom Regime, or UK tax matters in general, then please get in touch.
In a strategic move to bolster economic stability, the Argentine government, through Decree No. 281/2024 published on 27 March 2024, has extended an attractive incentive for the repatriation of financial assets held abroad by its citizens.
Originally set to conclude by 31 March 2024, the deadline for this initiative has now been extended to 30 April 2024, allowing taxpayers additional time to benefit from favorable Personal Assets Tax (PAT) rates.
The essence of this decree lies in its provision for equalizing the PAT rates for assets located abroad with those within Argentina.
To qualify for this benefit, taxpayers must repatriate at least 5% of their total financial assets held overseas before the new deadline.
This move is aimed at encouraging the return of capital to the country, thereby injecting liquidity into the national economy.
To enjoy the harmonized tax rates, the repatriated funds must be:
The decree ensures that assets repatriated and meeting the specified conditions will be subject to the same PAT rates as those applicable to domestically located assets, potentially leading to significant tax savings for individuals.
This is in contrast to the higher rates traditionally applied to assets located abroad, thus providing a substantial incentive for the repatriation of assets.
For assets located within Argentina, the tax rates range from 0.50% to 1.75% for assets exceeding specific thresholds, providing a graduated tax scale based on the total value of assets.
Conversely, assets held abroad are subject to rates ranging from 0.70% to 2.25%, depending on the combined value of domestic and foreign assets.
This decree represents a pivotal effort by the Argentine government to repatriate capital, promoting investment within the country.
By offering a streamlined and financially advantageous process, Argentina aims to strengthen its economic foundations and foster a more robust investment climate.
If you have any queries about this article on Tax Incentives for Repatriation of Financial Assets, or tax matters in Argentina more generally, then please get in touch.
Under Canada’s taxation system, your residency status plays a pivotal role in determining your income tax obligations and entitlements.
Whether you’re a Canadian citizen, a permanent resident, or a foreign national, understanding the factors influencing tax residency is crucial.
This article explores some of the considerations involved in determining tax residency status in Canada.
The Canadian Revenue Agency (CRA) assesses various factors, known as “residential ties,” to determine an individual’s tax residency status.
These ties can be categorized into primary and secondary ties
These include the location of a primary dwelling, spouse or common-law partner, and dependents.
Secondary ties encompass personal property in Canada, social and economic ties with Canada, immigration status, healthcare coverage, driver’s license, vehicle registration, and memberships in Canadian organizations.
While primary ties carry significant weight, secondary ties are also considered collectively to ascertain residency status accurately.
The duration of an individual’s stay in Canada within a tax year is a crucial factor in residency determination.
Spending 183 days or more in Canada during a tax year typically results in Canadian residency for tax purposes.
However, even shorter stays can impact residency status when coupled with primary and secondary residential ties.
In cases of dual residency, where an individual is considered a resident of both Canada and another country for tax purposes, treaty tie-breaker rules apply.
These rules help resolve conflicts in residency status and prevent double taxation by considering factors such as the individual’s permanent home, center of vital interests, habitual abode, and nationality.
Based on the above criteria, individuals are categorized into three residency status groups by the CRA:
Individuals with significant residential ties to Canada are subject to Canadian income tax on their worldwide income.
Those lacking significant residential ties are subject to Canadian tax solely on Canadian-source income.
Certain individuals not meeting residency criteria may be deemed residents under specific circumstances, such as establishing significant ties to Canada without residency in another country under a tax treaty.
If uncertain about residency status, individuals can seek guidance from tax professionals and utilize CRA forms like Form NR74 (Entering Canada) or NR73 (Leaving Canada) to assess ties to Canada.
Advanced income tax rulings from the Income Tax Rulings Directorate offer further assurance, although they require thorough documentation and are legally binding.
Determining one’s tax residency in Canada is no simple task and the result will have significant implications for a taxpayers tax obligations and entitlements.
If you have any queries or comments on this article, or on any other Canadian tax issues, then please get in touch.
Like any tax system, Albania’s tax rules come with critical dates for taxpayers with April 30 being one of the most significant.
This marks the deadline for the declaration and payment of Personal Income Tax through the Annual Individual Tax Declaration (DIVA) for the previous fiscal year.
Understanding the DIVA process is essential for both residents and non-residents alike, as it carries legal obligations and implications.
The DIVA declaration process for the fiscal year 2023 remains consistent with previous years, maintaining similar categories and obligations.
Despite upcoming changes with the implementation of the new “Income Tax” law in 2025, which will affect declarations for the fiscal year 2024, the current process remains unchanged.
The Albanian Tax Authorities issue reminders to both resident and non-resident individuals who meet specific criteria.
Those with an annual gross income exceeding ALL 2,000,000 in 2023 or individuals engaging in moonlighting activities for at least one tax period within the year are legally obligated to complete the “Annual Individual Income Statement” as part of the DIVA process.
It’s crucial to note exemptions for individuals classified as ‘self-employed’ and those employed by an entity, whether an individual or a legal entity, from whom they receive income in the form of wages and employment-related benefits.
These individuals are exempt from declaring the DIVA, justified by the ‘self-employed’ category’s responsibility for paying social and health insurance, with their ‘Gross Salary’ section specified as zero.
The DIVA 2023 declaration includes pre-filled data regarding annual gross income from wages or benefits derived from employment relationships for individuals.
Additionally, the calculation of Income Tax from Employment is provided.
While prefilled, these sections are editable fields, enabling declarants to review and make necessary changes.
Moreover, the amount paid during the year related to Income Tax from Employment is prefilled, streamlining the declaration process.
Beyond its legal obligation, income declaration offers individuals an additional guarantee regarding the justification of their wealth.
It fosters transparency and accountability while ensuring compliance with tax regulations.
As April 30 approaches, it is important that you ensure that you fulfill your DIVA obligations to avoid penalties and remain compliant with Albanian tax laws.
If you have any queries about Albania’s DIVA Tax Declaration, or Albanian tax matters in general, then then please get in touch
The Sostegni Ter (Dl 4/2022) has brought changes to the flat tax rules for new resident retirees in Italy.
Let’s have a closer look at these changes.
Italian law offers a privileged tax regime to individuals receiving foreign pensions who wish to transfer their tax residence to Italy, specifically to municipalities with a population not exceeding 20,000 inhabitants in certain regions.
These regions include Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise, Puglia, among others.
Under this regime, foreign retirees can benefit from an optional tax rate of 7%, regardless of the type of income generated abroad, for each of the nine tax periods during which the option is valid.
This favourable tax treatment also extends to individuals relocating to municipalities affected by serious seismic events, such as L’Aquila, as well as smaller municipalities like Camerino, Matelica, Tolentino, and Norcia.
To aid in identifying eligible municipalities, the “Annual municipal survey of population movement and calculation” is published on the Istat website on January 1st of the preceding year.
Operational procedures for the flat tax, including exercise methods, revocation, and cessation of effects, are outlined by the Revenue Agency.
The flat tax is formalised through the submission of the income tax return for the tax period in which the individual transfers their tax residence.
The taxpayer must meet five requirements, including non-resident status in Italy for at least five tax periods prior to the start of the option’s validity and reporting foreign source income subject to the substitute tax.
The favourable effects of the flat tax cease after five years following the tax period in which the option was exercised.
However, taxpayers can revoke the choice made in subsequent tax periods directly in the income tax return.
Clarifications from the Italian Revenue Agency confirm that the 7% flat tax applies to all retirees, regardless of nationality, receiving a foreign pension, including those receiving an INPS pension.
Loss of eligibility for the regime may occur due to failure to meet requirements, omission of tax payment, transfer to a non-eligible municipality or abroad, or emergence of Italian tax residence in the preceding five years.
No doubt the Italian flat tax regime for foreign pensioners will prove attractive to those who are looking to retire overseas.
If you have any queries about the Italian Flat Tax for New Resident Retirees, or Italian tax matters more generally, then please get in touch.