Tax benefits of Cyprus Trusts

Tax benefits of Cyprus Trusts In order to become a modern and prestigious financial center and trust territory, Cyprus has established the so called “Cyprus International Trusts” (“CIT”), which have the following features: The “settlor” and the beneficiaries must not be permanent residents of Cyprus, however they may become residents after the creation of the […]

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Treatment of BONT in the new Uruguayan legislation

Treatment of BONT in the new Uruguayan legislation One of the changes introduced by the Tax Transparency Law (Law No. 19,484) enacted on January 05, 2017 is in regard to the treatment of the jurisdictions or regimes considered low-tax or no-tax (Baja o Nula Tributación, “BONT”, for its acronym in Spanish). Chapter III of said […]

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Life Insurance Regime in Puerto Rico

Life Insurance Regime in Puerto Rico Puerto Rico is an Associated State of the United States of America and although it has autonomy to issue certain regulations, due to the application of the Territorial Clause of the US Constitution, it is subject to certain rulings of the Congress. Therefore, matters such as banking and insurance […]

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BONT Jurisdictions in Uruguayan legislation

BONT Jurisdictions in Uruguayan legislation ¿What is a BONT jurisdiction or regime? According to Decree of the Executive Power No. 40/2017 of February 13, 2017, a jurisdiction or regime is considered low-tax or no-tax (“(Baja o Nula Tributación, “BONT”, for its acronym in Spanish) when the effective tax rate on income is lower than 12%; […]

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Deemed dividends in the Uruguayan National Budget Act

Deemed dividends in the Uruguayan National Budget Act The Uruguayan National Budget Act No. 19.438 of fiscal year 2015, was enacted on October 14, 2016 and began to be effective on January of the current year. Said law sets a series of amendments to different norms among which are those related to income tax. Among […]

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Main tax benefits of Malta

Main tax benefits of Malta The European Island of Malta offers the following benefits to take into account when addressing an estate planning engagement: Malta is a Member State of the European Union: is member of the block since 2004, of the Eurozone since 2008 and of the Schengen Area since 2007. It has double […]

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Differences between FATCA and CRS

Differences between FATCA and CRS FATCA: Foreign Account Tax Compliance Act FACTA was enacted by the Congress of the United States on 2010 and is an Act that intends to identify US persons and residents that have money outside the country, thus achieving control over the compliance of tax obligations of US taxpayers. The implementation […]

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Changes in The Netherlands’ regulations providing for the Ultimate Beneficial Owners Register (“UBO” for its initials in English)

Changes in The Netherlands’ regulations providing for the Ultimate Beneficial Owners Register On May 20,  2015, the European Union adopted the Fourth Directive on anti-money laundering (hereinafter the “Directive”), which among other things sets forth the implementation of a central register of ultimate beneficial owners of the companies and trusts registered in territories of Member […]

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A Summary of the Barbados Corporate and Trust Service Providers Act

A Summary of the Barbados Corporate and Trust Service Providers Act The Corporate and Trust Service Providers Act came into force on November 1º, 2015, and its purpose is to promote and maintain high standards of behavior, ethics and competence in the rendering of corporate and trust services. Additionally, the aim of this act is […]

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Summary on BEPS

Summary on BEPS Base erosion and profit shifting (“BEPS”) are tax practices used by multinational companies to shift their profits to low or no tax jurisdictions, due to the existence of legal gaps in tax matters that ease the avoidance of double taxation of income. In order to look for solutions that eliminate said practice, the […]

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