WTax’s Post

This an important update on Portugal ECJ claims, a landmark ruling in 2024 now paves the way for US investment funds to succeed in the market but all non-EU funds can take advantage of the opportunity! #InternationalTax

Tax efficiency is often a key factor for investors when selecting where to allocate their capital, as it directly impacts the net returns of an investment fund. Staying informed on the latest rulings from the European Court of Justice (ECJ) is essential, as these decisions can significantly influence the regulatory and tax landscape. Failing to stay current with ECJ developments may result in missed opportunities and suboptimal outcomes for both you and your investors. Being proactive in this area is not just beneficial—it’s imperative for maintaining a competitive edge in the market. Can WTax help?

Great news for your investments in Portugal! Did you know investment funds can challenge unfair tax practices with help from the European Court of Justice (ECJ)? There’s now a big opportunity to recover withheld taxes, and while the process can be tricky, the potential to increase returns and boost fund performance is huge. Recent rulings in Portugal give non-EU investment funds a strong case to fight unfair tax practices. At WTax, we’re experts in guiding you through these legal processes to help maximize your tax recoveries. Interested in learning more? Let’s talk! #WithholdingTax #TaxReclaim #WTax #InvestmentFunds https://lnkd.in/dWvHX5PM

📢 𝘍𝘪𝘯𝘢𝘯𝘤𝘪𝘢𝘭 𝘚𝘦𝘳𝘷𝘪𝘤𝘦𝘴 𝘛𝘢𝘹 𝘈𝘭𝘦𝘳𝘵: 𝘌𝘜 𝘊𝘰𝘮𝘮𝘪𝘴𝘴𝘪𝘰𝘯 𝘪𝘯𝘪𝘵𝘪𝘢𝘵𝘦𝘴 𝘪𝘯𝘧𝘳𝘪𝘯𝘨𝘦𝘮𝘦𝘯𝘵 𝘱𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦 𝘢𝘨𝘢𝘪𝘯𝘴𝘵 𝘵𝘩𝘦 𝘕𝘦𝘵𝘩𝘦𝘳𝘭𝘢𝘯𝘥𝘴 On July 25, 2024, the European Commission launched an infringement procedure against the Netherlands, challenging its discriminatory tax laws that favor domestic over foreign investment funds. This could lead to significant changes in Dutch taxation practices, particularly affecting withholding tax (WHT) for foreign multi-investor investment funds. 𝐊𝐞𝐲 𝐇𝐢𝐠𝐡𝐥𝐢𝐠𝐡𝐭𝐬: ◼️ 𝘋𝘶𝘵𝘤𝘩 𝘞𝘏𝘛 𝘙𝘦𝘤𝘭𝘢𝘪𝘮𝘴: The infringement procedure may compel the Netherlands to revise its withholding tax regime, which currently excludes foreign investment funds from WHT reductions granted to domestic funds (INFR 2024/4017). ◼️ 𝘖𝘱𝘱𝘰𝘳𝘵𝘶𝘯𝘪𝘵𝘪𝘦𝘴 𝘧𝘰𝘳 𝘍𝘰𝘳𝘦𝘪𝘨𝘯 𝘍𝘶𝘯𝘥𝘴: Foreign funds may now have an increased chance of reclaiming WHT suffered in the Netherlands. WTS recommends timely fund-level applications for multi-investor funds and re-evaluating WHT threshold amounts. WHT refund applications for 2021 must be filed by the end of 2024 to avoid time-bar restrictions. 🔗 𝐑𝐞𝐚𝐝 𝐦𝐨𝐫𝐞: https://lnkd.in/dWVUyMd9 🔍 For more information, feel free to contact our colleagues at WTS Deutschland, Steffen Gnutzmann, and Jonas Carstensen. WTS Global Locally rooted - Globally connected #wts #wtsglobal #tax #taxation #taxnews #taxinsights #corporatetax #financialservices #WHTReclaims #FundTaxation #EUCommission #netherlands

Investing in Mutual Funds by Singapore NRIs can help them in saving capital gains tax on sale of mutual fund. However one needs to be mindful of the provisions of the Double Taxation Avoidance Agreement (DTAA) between India & Singapore and fullfil the requirements thereunder to avoid future litigation. #taxation #dtaa #internationaltaxation #nri #capitalgains https://lnkd.in/d-iWEJVN

Curacao enhances its appeal as a prime location for investment funds. The attached alert details several significant amendments to Curacao's tax laws that enhance its attractiveness as a location for investment funds. Firstly, partnerships, including limited partnerships, are now considered transparant entities and are not subject to Curacao profits tax. However, partners of a limited partnership (known locally as a "commanditaire vennootschap" or CV) may opt for the entity to be taxable under Curacao's profits tax regime. Additionally, the substance requirements have been abolished for investment vehicles that are registered with the Central Bank of Curacao and St Martin (CBCS). In a separate mandate, Curacao has established a register for Ultimate Beneficial Owners. It should be noted however, that this UBO register will not be accessible to the general public.

[ Offshore Tax ] Thoughts on Singapore's Irrevocable Trusts. A Singapore irrevocable trust is a legal arrangement in which the settlor, transfer ownership of assets to a trustee for the benefit of designated beneficiaries. The term "irrevocable" means that you cannot change your mind later and reclaim ownership of the assets placed in the trust. KEY CHARACTERISTICS OF A SINGAPORE IRREVOCABLE TRUST Benefits: 1. Asset Protection: Assets placed in the trust are generally protected from the creditors of the settlor, potentially shielding them from lawsuits or bankruptcy. 2. Tax Planning: Depending on the structure of the trust, it may offer some tax advantages, such as reducing estate duty or income taxes. 3. Succession Planning: The trust allows you to control how assets are distributed to your beneficiaries after your death. This can help avoid probate and ensure your wishes are followed. Considerations: 1. Loss of Control: Once assets are transferred to the trust, you relinquish control over them. The trustee manages the assets according to the terms of the trust deed. 2. Cost: Setting up and maintaining a trust can involve legal and administrative fees. 3. Tax Implications: While there may be some tax benefits, it is crucial to seek tax advice to understand the potential tax consequences for the settlor, the trustee, and the beneficiaries. #SingaporeTrust #IrrevocableTrust #AssetProtection #TaxPlanning #SuccessionPlanning #EstatePlanning #FinancialSecurity #TrustBenefits #WealthManagement #LegalConsiderations #TrustAdministration #FinancialPlanning #TaxAdvisory #WealthPreservation #Trusteeship

[ Offshore Tax ] Thoughts on Singapore's Irrevocable Trusts. With Mark Morris and Derren Joseph EA #SingaporeTrust #IrrevocableTrust #AssetProtection #TaxPlanning #SuccessionPlanning #EstatePlanning #FinancialSecurity #TrustBenefits #WealthManagement #LegalConsiderations #TrustAdministration #FinancialPlanning #TaxAdvisory #WealthPreservation #Trusteeship

[ Offshore Tax ] Thoughts on Singapore's Irrevocable Trusts. With Mark Morris and Derren Joseph EA #SingaporeTrust #IrrevocableTrust #AssetProtection #TaxPlanning #SuccessionPlanning #EstatePlanning #FinancialSecurity #TrustBenefits #WealthManagement #LegalConsiderations #TrustAdministration #FinancialPlanning #TaxAdvisory #WealthPreservation #Trusteeship

Great insight into the recently finalised PCG on intangibles migration. This is an area of recent ATO activity and contains important considerations for Australian taxpayers entering into restructuring events with their international related parties. #ato #internationaltaxation #internationaltax #transferpricing #intangibles https://lnkd.in/eviputPX