Tax Treaties  Tax treaties are introduced in order to avoid double taxation.   Let’s say that you have a company in Canada but are also doing some business in the USA, so you have an office there. So the USA will want to tax you because you have an office there, but Canada also wants to…

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International tax planning for Italians    Any time we look at international tax planning we want to pay attention to the three pillars of residency:    -Residency of the company. You will want to have a company that’s outside of the country in order to decrease the amount of tax paid.   Italy’s base tax rate…

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Participation exemption  Traditionally if you had dividends paid to you from a company that would be taxable.   Very often you’d have that company owned by another company and they would receive dividends tax free.   The question is what if that company was foreign?    Let’s imagine you have a company in Bahamas, and that company…

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Tax avoidance VS Tax evasion  Lots of people have misunderstandings when it comes to terms tax avoidance and tax evasion. They are not really certain whether those are synonyms or not.   Let’s make it clear – Tax avoidance and tax evasion are two different things!    Tax avoidance is fine, it is completely legal while…

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What is substance    Substance is getting more and more important. We witnessed tighter and stricter regulations is the recent years, and we can only expect it to go worse with time.  So what is actually substance?   Well, it means that you have something going on behind your structure.   Traditionally, the most popular place for…

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CRS and Automatic exchange of information Today we are talking about the advantage that Montenegro currently has that attracts people to come and bank here. What we mean here is automatic exchange of information and common reporting standards. Well, those will not be your issues if you are here.     In 2009. bank secrecy around…

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What is Residency?    When we talk about residency for tax purposes and you only live and do business in one country the rules that apply are very simple.   If you are a resident of Canada (you live there) Canadian tax rules apply.   As you start to do business in multiple countries, have customers elsewhere,…

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Inheritance tax in the UK is the tax that one is liable to pay on any assets which a deceased person has passed on to a legal heir or inheritor. These assets could include property, money, investments, vehicles, payouts from life insurance policies, and any other possessions. When a person dies, the government estimates the…

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Things to consider when building an international structure  It’s very important thing to note from the beginning that there is no one size fits all structure for a business, investment, operation, etc.   Every case is different and there are lots of things to consider:   Who are the owners?  Who are the customers?  Where are the suppliers?  What type of business is it?  Where…

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What is “Withholding Tax”?    Most people only think of one, in some cases two layers of tax.  In fact, we generally, have three layers of tax to consider whenever we’re doing international tax planning and structuring.   The first layer is corporate income tax, which is what most people are trying to reduce by going to a low or zero…

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