Andorra, Argentina, Australia, Bermuda, Brazil, Canada, Cayman Islands, Channel Islands: Guernsey, Channel Islands: Jersey, China, Cyprus, Dominican Republic, France, Germany, India, Indonesia, Ireland, Isle of Man, Israel, Italy, Japan, Luxembourg, Mexico, Pakistan, Russian Federation, Singapore, South Africa, South Korea, Switzerland, The Netherlands, Turkey, USA, United Kingdom, Venezuela
Australia, Bermuda, Brazil, Canada, Cayman Islands, Channel Islands: Guernsey, Channel Islands: Jersey, China, Cyprus, Dominican Republic, France, Germany, India, Indonesia, Ireland, Isle of Man, Israel, Italy, Japan, Luxembourg, Mexico, Pakistan, Russian Federation, Singapore, South Africa, South Korea, Switzerland, The Netherlands, Turkey, USA, United Kingdom, Venezuela
Step 1: Check the boxes to select the questions and the jurisdictions for comparison.
Step 2: Click the "submit" button.
Step 3: Scroll down to view answers and check law stated dates for each jurisdiction.
Tax year and payment dates
When does the official tax year start and finish in your jurisdiction and what are the tax payment dates/deadlines?
Domicile and residence
What concepts determine tax liability in your jurisdiction (for example, domicile and residence)? In what context(s) are they relevant and how do they impact on a taxpayer?
Taxation on exit
Does your jurisdiction impose any tax when a person leaves (for example, an exit tax)? Are there any other consequences of leaving (particularly with regard to individuals domiciled in your jurisdiction)?
Does your jurisdiction have any particular tax rules affecting temporary residents?
Taxes on the gains and income of foreign nationals
How are gains on real estate or other owned by a foreign national taxed? What are the relevant tax rates?
How is income received by a foreign national taxed? Is there a withholding tax? What are the income tax rates?
Inheritance taxes and lifetime gifts
What is the basis of the inheritance tax or gift tax regime (or alternative regime if relevant)?
What are the inheritance tax or gift tax rates (or alternative rates if relevant)?
Does the inheritance tax or gift tax regime apply to foreign owners of real estate and other assets?
Are there any other taxes on death or on lifetime gifts?
Taxes on buying real estate and other assets
Are there any other taxes that a foreign national must consider when buying real estate and other assets in your jurisdiction?
What tax-advantageous real estate holding structures are available in your jurisdiction for non-resident individuals?
Taxes on overseas real estate and other assets
How are residents in your jurisdiction with real estate or other assets overseas taxed?
International tax treaties
Is your jurisdiction a party to many double tax treaties with other jurisdictions?
Is it essential for an owner of assets in your jurisdiction to make a will in your jurisdiction? Does the will have to be governed by the laws of your jurisdiction?
What are the formalities for making a will in your jurisdiction? Do they vary depending on the nationality, residence and/or domicile of the testator?
What rules apply if beneficiaries redirect their entitlements?
Validity of foreign wills and foreign grants of probate
To what extent are wills made in another jurisdiction recognised as valid/enforced in your jurisdiction? Does your jurisdiction recognise a foreign grant of probate (or its equivalent) or are further formalities required?
Death of foreign nationals
Are there any relevant practical estate administration issues if foreign nationals die in your jurisdiction?
Administering the estate
Who is responsible for administering the estate and in whom does it initially vest?
What is the procedure on death in your jurisdiction for tax and other purposes in relation to:
Establishing title and gathering in assets (including any particular considerations for non-resident executors)?
Are there any time limits/restrictions/valuation issues that are particularly relevant to an estate with an element in another jurisdiction?
Is it possible for a beneficiary to challenge a will/the executors/the administrators?