Minimum substance test under EU shell company directive In December 2021, the European Commission (EC) published its draft Council Directive, amending Directive 2011/16/EU (the Directive) and setting out the rules to prevent the misuse of shell entities for tax purposes. The EC has observed that certain individuals and some businesses direct their income to shell...Read More

DTA amendment in the pipeline for Russia and Switzerland Following Russia’s recent request to revise the existing double taxation agreement (DTA) with Switzerland, the two Countries’ finance ministers have held a meeting to initiate discussion upon the matter. Starting from 2020, Russia has renegotiated a number of DTTs (as with Malta, Luxembourg and Cyprus), increasing...Read More

Mauritius: foreign trusts no longer exempt from income taxes With the amendment of the country’s Finance Act (Miscellaneous Provisions) the Mauritius Revenue Authority (MRA) has recently announced that foreign trusts held within the country will no longer be exempt from income taxes. This means that even if you are a non-resident your will be required...Read More

Abusive trust arrangements targeted by Australian Authorities After collecting more than AUD 22.9 billion in liabilities against multinationals, wealthy individuals, trusts and public groups, the Australian Tax Office’s (ATO’s) tax avoidance taskforce aims to focus on ‘abusive trust arrangements’ and their promoters. Specifically, the agency will tackle HNWI and groups have seeking to exploit tax...Read More

UK’s TRS opens to non-taxable trusts and extends reporting deadline The UK’s Trust Registration Service is now open for non-taxable trusts to register, bringing under its scope all UK express trusts and certain non-UK express trusts, with the exclusion of: a. UK-registered charities; b. will trusts limited to two years; c. life policies; d. trusts...Read More