New Zealand Trust as an Estate Planning Vehicle

New Zealand Trust as an Estate Planning Vehicle What is a trust? Is an agreement under common law where a person (“settlor”) transfers assets to an independent party (“trustee”), who will than be authorized to manage said assets in benefit of the beneficiaries of the trust. The settlor is the person who creates the trust […]

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Tax Residency in Uruguay

Tax Residency in Uruguay Uruguay is an attractive country if one is contemplating complete estate planning that includes the place of residence of the individual, especially considering its tax regime based on the territoriality or source principle. The tax residency concept in Uruguay was introduced by the tax reform law number 18.083 of 2007. Due […]

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The CFC Rules within the context of the International Tax Transparency

The CFC Rules within the context of the International Tax Transparency The Controlled Foreign Company Rules are features of a tax system designed to limit the artificial deferral of taxable income by using offshore companies with low or no imposition of tax. They originated since international tax norms followed a general tendency where the income […]

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A look to the Special Economic Zones

A look to the Special Economic Zones For almost three years now the Uruguayan Parliament has been working on the amendment project of the Free Trade Zones regime contained in Law 15.921 of year 1987. Taking into account the efficiency of the norms in force, it intends to deepen the obtained benefits adapting the regime […]

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Contributed capital in Spanish Companies

Contributed capital in Spanish Companies In Spain, contributions to a company are those equity elements (whether monetary or not) contributed by the partners. The capital stock increase is a voluntary transaction. Modes: Monetary contribution:  Monetary contributions must be set in Euros (or its equivalent in Euros). The authenticity of the contribution must be certified before […]

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Tax Amnesty to Brazilian Non-Declared Offshore Funds

Tax Amnesty to Brazilian Non-Declared Offshore Funds On March 15, Normative Ruling No. 1627 regulating what has been named “Regime Especial de Regularização Cambial e Tributária (RERCT)” set by Law No. 13.254/16 was published. This ruling is currently being reviewed by the Federal Supreme Court. The Normative Ruling opens up a tax window from 4.4.2016 […]

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Frequently asked Questions on Automatic Exchange of Information

Frequently asked Questions on Automatic Exchange of Information Which is the initial date for the automatic exchange of information and which are the jurisdictions? In September 2017, a first group of countries will be in a position to begin the automatic exchange of information. There is a second group that is expected to exchange information […]

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BVI’s Business Companies Act Reform

BVI’s Business Companies Act Reform Starting January 15, 2016 the Law that modified various aspects of the BVI Business Companies Act 2004 entered into force. The main amendment introduced by said law is summarized as follows: Creation of a Private Registry of Directors Starting April 1st, 2016, BVI’s companies must declare who their Directors are […]

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Uruguay: Towards the automatic information exchange

Uruguay: Towards the automatic information exchange In June 2014, the OCED (Organization for Cooperation and Economic Development) approved the text of the rules known as Common Reporting Standard that imply the existence of a global standard for automatic exchange of information. After said approval, several countries had an early implementation, while another 96 countries, at […]

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Spanish Holding Facelift

Spanish Holding Facelift Legislative changes and current economic trends give life to Iberian companies When talking about tax planning nothing is new about Spanish Holding Companies Since 2004, when the restated text of the Corporations Tax Law was approved by Legislative Decree 4/2004 the FSHE regime was created – (Foreign Securities Holding Entities)- the appearance […]

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