TAG Tax


Recent amendments to Philadelphia’s realty transfer tax will likely change the way commercial real estate is bought and sold. Rather than sell the real estate directly and record a traditional deed to evidence the transaction, it is common practice to sell ownership interests in the company that holds title to the real estate. This approach often significantly reduces the realty transfer tax due as a result of the transaction because the value used to compute the tax is based on the property’s assessed value, which is often lower than the purchase price for the company. Moreover, selling less than 90% of the equity in the company does not trigger any tax at all, provided the seller holds the remaining equity for at least three years.

Read more: Amendments to Philadelphia's Realty Transfer Tax Will Have a Significant Impact


On 1 November 2016 the amendments to the Income Tax Act entered into force in Estonia adopting the amendments of the EU Directive No. 2011/96/EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (hereinafter the Directive). The aim is to apply the general anti-abuse clause regarding the division of profits between parent companies and subsidiaries as well as to avoid double non-taxation with regard to hybrid loans.

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Introduction

The effects of globalization and increased capital mobilization have forced most states to take extreme measures when tracing international transactions of taxpayers in order to combat base erosion and harmful tax competition. The differing tax ratios applied by states as a result of their tax policies made it possible for certain taxpayers to conclude their transactions with significantly lower tax burdens. In the aftermath of the economic crisis of 2008, the states all around to world were incentivized to cooperate in order to take measures to prevent wealthy individuals and entities to park their capital to tax havens in order to evade paying tax. More recently, the Panama Papers[1], a massive amount of confidential documents leaked on April 2016, attracted global attention to tax secrecy and tax havens.

Read more: Information Exchange under Turkish Tax Law


It was Theresa May's first Autumn Statement as Prime Minister, Phillip Hammond's first as Chancellor of the Exchequer and the UK's first since the referendum confirming that the UK will be leaving the EU. However, there wasn't much in terms of "firsts" for the content of the Autumn Statement itself, with many measures being known about already. It doesn't seem as though Mr Hammond consulted our wish list of what we wanted to see for our private clients.

Read more: The UK Autumn Statement 2016: What this means for private clients


Introduction

Violation of the provisions of tax codes may result in the imposition of tax penalties (tax evasion and non-compliance penalties) stipulated under the Tax Procedure Code (“TPC”), as well as other liberty bindings and monetary fines that fall within the scope of the criminal courts.

Read more: Dismissal of Tax Penalties in Turkey