March 28, 2023

Bittersweet Christmas in Spain – Beckham Regime 2.0 and Solidarity Tax

March 28, 2023/ Ruchelman P.L.L.C.

Last year, Christmas in Spain brought with it good news for some individuals and bad news for others. Regarding the good news, the Beckham Regime was improved as was the start-up ecosystem regime for entrepreneurs. Regarding the bad news, Spain adopted a second wealth tax to soak up wealth tax that appropriately went unpaid where certain regions provided relief for assets situated in the local region. Spanish residents that previously paid no Wealth tax will be subject to the Solidarity tax. Luis J. Durá Garcia, the Managing Partner of Durá Tax & Legal, Madrid and Valencia, tells all.

March 28, 2023

Teleworking From Bulgaria: Different Arrangements Have Different Consequences

March 28, 2023/ Ruchelman P.L.L.C.

Bulgaria has benefitted as a preferred remote working location for digital businesses. While it does not have a digital nomad visa for work, it has a cadre of skilled individuals working as computer engineers available to be employed by foreign based multinationals. In their article, Viara M. Todorova, a Partner of Djingov, Gouginski, Kyutchukov & Velichkov, Sofia, and Ivan Punev, a Senior Associate at Djingov, Gouginski, Kyutchukov & Velichkov, Sofia explain the specific tax issues that face a foreign company looking to engage local talent to carry on functions from Bulgaria. Several different arrangements are common, and each has its own set of employment tax obligations for the service provider and the company. Adding to the mix, the threshold of activity in Bulgaria that creates a P.E. is relatively low and the choice of arrangement can affect the outcome.

March 28, 2023

Let's Talk About Nomad Employees!

March 28, 2023/ Ruchelman P.L.L.C.

Over the years, a consensus developed overseas that the U.S. doeEmployees working from overseas is hardly a new phenomenon. However, the COVID-19 pandemic forced employees to work remotely. Indeed, some were forced to work abroad under lockdown or shelter-in-place rules. Not surprisingly, remote working morphed into nomad employees choosing to work from anywhere, any place, in any time zone. The hiring of remote employees brings with it exposure to all sorts of remote taxes for the employer in each place where a remote worker is based. Is there a P.E. for corporate income tax? Is there a fixed base for V.A.T.? Are there income tax withholding obligations for compensation payments? Are there social security obligations? Martin Phelan, a Partner in the Dublin Office of Simmons & Simmons where he is Head of Tax, and Fiachra Ó Raghallaigh, an Associate in the Dublin Office of Simmons & Simmons, provide big picture commentary. Interestingly, the United Nations Tax Committee is examining the policy issues that face nations and employers.

January 30, 2023

Major International Tax Reform in Israel – Proposal Takes Aim at Tax Residence Rules

January 30, 2023/ Ruchelman P.L.L.C.

In November 2021, the Israel Tax Authority Committee for International Tax Reform published a report proposing substantial reform to international tax rules in Israel. Regarding rules for determining tax residence in Israel, the purported goal was to simplify the rules for determining an individual’s tax residence. To that end, it introduces a day-count rule as a supplement to the existing center-of-vital-interest rule. Boaz Feinberg, a Partner of Arnon, Tadmor-Levy Law Firm in Tel Aviv and Rosa Peled, an associate at the law firm of Arnon, Tadmor-Levy Law Firm in Tel Aviv, explain that for most taxpayers, the center-of-vital-interest rule will continue to apply. However, because assessing officers will no longer address cases at the fringes, where the day-count rule is applied, more assessing offices can free-up to examine the remaining cases based on the center-of-vital interest rule.