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INTERNATIONAL - AUSTRALIA: Consequences of using foreign trusts for capital gains

The Japanese government's 2018 tax reform bill abolishes the recently introduced rule under which the heirs of a long-term resident foreigner who died outside Japan remain liable to Japanese inheritance tax (IHT) on estate assets anywhere in the world. The rule had threatened to derail the government's efforts to attract foreign talent to live and work in Japan, because it meant IHT liability could follow a foreign national for up to five years after leaving the country.

INTERNATIONAL - JERSEY: Apple says relocation of Irish subsidiary does not reduce its tax liabilities

INTERNATIONAL - GERMANY: Restriction of loss relief declared unconstitutional

INTERNATIONAL - European Union: Taxation at source must take into account non-resident taxpayer's domestic costs

As from 1 January 2006, it has been possible to meet the taxation requirements on some real estate transfers at the land registry's valuation, regardless of the price agreed and shown in the contract. The rule that first introduced the price-value concept was Article 1, Paragraph 497 of Law no. 266 of 23 December 2005 (2006 Budget); there were two subsequent amendments: Article 35, Paragraph 21 of Legislative Decree no. 223 of 4 July 2006, converted with modifications into Law no. 248 of

In "land credit" contracts, the borrower has the legally-assured option of early repayment of the home loan; but generally, even in ordinary contracts, that possibility is foreseen. The borrower may decide, therefore, at a certain point in the repayment plan, to close out the contract and repay the remaining capital, on which obviously he will no longer pay interest. Given this loss of earnings, the bank could, if the contract so stipulates, demand compensation (a penalty). According to a

In order to avoid the notary's fees, which like any other professional service are calculated on the real price, becoming a possible disincentive for the application of the new rule, the lawmakers stipulated that those fees should be reduced; the reduction is set at 30 per cent. The National Council of Notaries, in order to ensure the full application of this new regulation and to meet the demands of Consumer Associations, has determined that the reduction should apply not only to the specific i

As has been seen above, in order to determine the type of tax and the amount and means of payment of the sums due for duties on the purchase of a so-called primary residence, one must first of all take into account the nature of the vendor. When the vendor is the company that built (or renovated) the property and four years have not elapsed since completion, the conveyance is subject to VAT that the purchaser must pay directly to the company and not to the notary, along with the payment o

Limited partnerships with share capital is a modified form of a company with share capital in which permanent directors manage the company who have unlimited liability, also contingent liability, for  social security liabilities. The provisions that are specific for this type of company are reduced to a few which concern above all the management of the company by the unlimited partners.    The peculiar characteristic of this type of company consists in the co-existence of two different group

Once upon a time it was enough to say that a foreigner was someone who was not an Italian citizen. This definition – to be clear – is still valid. Except that Article 17 of the EC Treaty institutes a citizenship of the European Union which is attributed to anyone who is a citizen of a Member State. Belonging to the European Union brings with it various consequences, some of which are very important, like the prohibition on

Take the case in which the company has lost capital. What is the company allowed to do?In this connection the law envisages that, in case of losses, the company cannot distribute profits among the partners until the capital has been reduced or replenished by the corresponding amount.However, unlike what happens for companies with share capital, there is no obligation to reduce the capital whatever the amount of the losses incurred, even if the latter are such as to wipe out the  entire capit