Viewpoints
2020-07-23
Setting Up a Single Family Office in Singapore Singapore is regarded as one of the most prominent financial centre in Southeast Asia because it is adjacent to local and global private banks, investment banks and other financial service providers. It is also known for its stable governance and favourable business environment, so it’s popular as a base for many high net worth families to manage assets and invest globally. The Singapore government has set up tax incentives for offshore and onshore funds managed by family offices to boost Singapore’s appeal as a leading wealth management centre. Please refer to our Introduction to Family Office in Singapore for more details. How to Set Up the Structure of a Single Family Office in Singapore？ A simplified description of the ownership structure of a typical family office is shown in the following figure: How Long Will it Take to […]
2020-07-23
Reporting Obligations for Chinese ODI Investors The Chinese overseas direct investment (ODI) investors are required to report their overseas investments data to the competent administration authorities in accordance with the laws and regulations when they have completed the filing or approving procedures for overseas direct investment. The competent administration authorities include the relevant commerce bureau, development and reform commission, foreign exchange administration bureau. Commerce Bureau The main reporting obligations to the competent commerce bureau include: (1) Reporting of the Registration Status of the Overseas Enterprise The responsible person of the overseas enterprise shall, within 30 days upon completion of its registration procedures abroad, report to and register with the business office of the local Chinese embassy or consulate with the registration form of overseas Chinese-funded enterprise (institution) and other relevant materials. The domestic investor of the overseas enterprise shall return the receipt of the registration […]
2020-07-23
Mainland China and Macau Arrangements on Avoiding Double Taxation and Preventing Tax Evasion Protocol with Respect to Taxes on Income The Fourth Protocol The fourth protocol to the “Arrangement between the Mainland of China and the Macau Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income” (hereinafter referred to as “The Fourth Protocol”) was signed in Macao on November 28, 2019 and effective from May 14, 2020. The Mainland China and Macao have completed the required domestic legal procedures for the entry into force of The Fourth Protocol. The Fourth Protocol has entered into force on May 14, 2020, but the provisions of Article 6 shall apply to income obtained on or after May 14, 2020, and the provisions of other articles shall apply to the income obtained on or after January 1, 2021. For the […]
2020-07-23
Guide to Application for Mainland China-Hong Kong Cross-border License Plate With the development of the Guangdong-Hong Kong-Macao Greater Bay Area, the number of ports between Guangdong province and Hong Kong increases a lot. The relevant government authorities of the two places have launched administration measures on the quotas for cross- boundary private cars accordingly. Kaizen hereby summarizes the latest regulations for the application of quota for Hong Kong and Guangdong cross-boundary private cars as follow for your easy reference. HK Cross-boundary Private Cars not using HK-Zhuhai-Macao Bridge (1) Requirements for Investors of foreign Invested Enterprises Foreign investors, investors from Hong Kong and Macao, whose total amount of tax paid in Guangdong province in the previous year meet the following conditions, may apply for quota for Hong Kong cross-boundary private cars: (a) may apply for the first quota if the total amount of tax paid in […]
2020-07-23
Classification of Chinese ODI Projects As more and more Chinese enterprises carry out overseas direct investment (ODI), China has updated and released a series of regulations and policies on overseas direct investment of enterprises in recent years. Kaizen has summarized the application procedures and reporting obligations involved in the two articles, Guidelines on the Approval or Filing of ODI by Chinese Enterprises and Reporting Obligations for Chinese ODI Investors. It is crucial for Chinese enterprises that are planning to carry out ODI activities to have a thorough understanding of relevant regulations and policies and prejudge the category and approval tendency of overseas investment projects. Kaizen hereby summarizes the classification of Chinese ODI projects and the relevant regulations for your easy reference. The ODI projects of Chinese enterprises are divided into three categories, i.e. the encouraged category, the restricted category and the prohibited category, in accordance with the Guiding Opinions […]
2020-07-17
Guide to Taiwan Other Taxes Commodity Tax (1) Scope of Taxation Commodities list in the “Commodity Tax Act”, whether manufactured domestically or imported from abroad shall be subject to commodity tax in accordance with this act except as otherwise provided by any other laws. The commodity tax levies depend on the type of goods, and the applicable tax rate or tax amount is also different (non-progressive tax rate). (2) Taxpayers The Commodity Tax is levied when the taxable goods upon departure from a manufacturer’s premises or when the imported taxable goods completed the customs duties payment. The following table shows the scope of taxation and responsible taxpayers under the commodity tax: Scope of Taxation and Taxpayers under Commodity Tax Scope of taxation Taxpayer Exception Commodities manufactured domestically Manufacturer Commodities manufactured under consignment contract Consignee (i.e. manufacturer) If the consignor is a manufacturer of taxable […]
2020-07-17
Guide to Taiwan Anti-Tax Avoidance Measures Introduction In view of many anti-tax avoidance measures have already been placed in the United States, EU countries and many other countries, Taiwan has set anti-tax avoidance measures such as transfer pricing and anti-thin-capitalization in accordance with international regulations. At the same time, the Income Tax Act regarding the addition of “controlled foreign companies” and “actual management offices” has also been passed, and the implementation date is yet to be announced. Transfer Pricing Taiwan referred to the transfer pricing guidelines and related measures of the OECD and the United States and European countries. Formulated and issued “Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm’s-Length Transfer Pricing” (hereinafter referred to as the “TPAS”) as the tax authority to investigate the result of transactions between the parties, whether there is an irregular basis. (1) Legal Basis According to […]
2020-07-14
U.S. Taxation of Foreign Investment in Real Estate Related Income Real estate is a tax-driven industry. Foreign investors, nonresident alien, who have purchased real estate property in the U.S. are subject to several tax and filing requirements. You are a nonresident alien, including foreign individuals or foreign business entities, if not meet the resident alien definition. According to the resident alien definition, you are a resident alien of the United States for tax purposes if you meet either the green card test or the substantial presence test for the calendar year (January 1-December 31). To meet substantial presence test, you must be physically present in the U.S on at least 183 days during the current year, or 183 days during the 3-year period that includes the current year (at least 31 days) and the 2 years immediately before that. This following content focus on U.S. taxation of real estate held directly by non-resident aliens, especially […]
2020-07-14
U.S. Employer Identification Number Guide The Employer Identification Number (EIN), also known as the Federal Employer Identification Number (FEIN) or the Federal Tax Identification Number (FTIN), is a unique nine-digit number (for example, 12-3456789) assigned by the Internal Revenue Service (IRS) to business entities operating in the United States for the purposes of identification. EIN just like a Social Security Number (SSN) for your personal identification number. The EIN number allows you to communicate with the Internal Revenue Service (IRS) in the dealing of all the tax matters of your company. You may also need EIN for bank account opening, business license application or other reasons. The EIN is issued by the Internal Revenue Service (IRS) upon application. You can apply for EIN via website, fax or mail. Expedited service is not available. To complete the application, you should prepare the Form SS-4 and submit it with your company’s […]
2020-07-14
U.S. Employer Identification Number Application Procedures and Fees Our service fee for handling the EIN application is USD300. The Employer Identification Number (EIN), also known as the Federal Employer Identification Number (FEIN) or the Federal Tax Identification Number (FTIN), is a unique nine-digit number (for example, 12-3456789) assigned by the Internal Revenue Service (IRS) to business entities operating in the United States for the purposes of identification. EIN just like a Social Security Number (SSN) for your personal identification number. The EIN number allows you to communicate with the Internal Revenue Service (IRS) in the dealing of all the tax matters of your company. You may also need EIN for bank account opening, business license application or other reasons. The EIN is issued by the Internal Revenue Service (IRS) upon application. You can apply for EIN via website, fax or mail. Expedited service is not available. To complete […]