Home - THE STEVEN PEPA BLOG

HNWIs seeking to leave the UK

An interesting read from Family Capital. Although I agree with the net-outflow thesis, the issue is where will these millionaires / billionaires go? America, for example, is starting to see a slow outflow of its ultra-wealthy as they increasingly feel

Hungary blocks global minimum tax

Hungary blocked an EU directive that would impose a 15% minimum tax on multinational corporations, arguing the levy would deal a "low blow" to European competitiveness and endanger jobs. The tax reform is part of a global deal achieved last

Why Malaysia’s failure on MM2H will result in decreased FDI interest

Last month, Malaysia placed new and more onerous compliance requirements on its MM2H (Malaysia My Second Home) program. As expected, this has resulted in significant concern in regards to future FDI (foreign direct investment) in the Malaysian economy. As I

When Investment Migration Programs Go Wrong.

An interesting quick read with respect to the Cyprus property market post-CIP. What the authors do not stress, and is evident on the ground, is the fact that when an investment migration program is artificially structured towards real property to

The Pending Paradigm Shift

Without trying to sound cliché, Karl Marx once wrote: "History repeats itself, first as tragedy, second as farce." This seems to be the state Western liberal democracies find themselves in these days. Big governments with bloated bureaucracies, high taxes and

Wealthy beware

I would argue that HNWIs both in Asia and the Americas should now start to look at effective investment migration strategies that allow one to hedge their bets. As this article in Asia Nikkei and the legislative proposals of Senators

For the 99.5% Act

On March 25, 2021, Senator Bernie Sanders introduced legislation entitled “For the 99.5% Act.” The aim of the bill is to tax the fortunes of the top 0.5% of wealthy Americans. This is the first piece of legislation introduced since

US attempts to create a global tax baseline

U.S. Treasury Secretary Janet Yellen argued this week for the imposition of a global minimum corporate tax rate. Her comments were set in the context of increasing U.S. corporate taxes to fund Joe Biden's USD $2 trillion+ infrastructure plan. Why do

Cyprus changes permanent residency program to reflect fund options

Cyprus has made some changes to its permanent residency by investment program. Quite a good step in the right direction. However, in order to be competitive, Cyprus must align its offering with that of Portugal or the new Bulgarian fast

Crypto & Taxes

Saw an interesting piece on crypto-currencies and tax regimes in Wealth Management. Worth the read.

FATCA and Foreign Bank Accounts

In the waning days of the Trump Presidency a little known act - the "Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2019" - was passed into law as part of the reconciled National Defense Authorization Act for Fiscal

NY Beware. Americans are looking elsewhere.

Came across an interesting piece in the New York Post regarding NY state legislature proposing an additional USD $7bn in new and increased taxes on businesses and the ultra wealthy. What legislatures continually fail to grasp is the fact that

Democrats push for a ‘Wealth Tax’

The United States has never had a wealth tax. European nations have had such things, but many of repealed them over the last few decades. Simply put, wealth taxes don't work for they spur capital flight. That has not deterred

Rich Indians are set to leave

With the more onerous tax burdens coming into play, the wealthy of India are looking for options. Many are still looking to the UK but with Brexit now a reality, a new and exciting opportunity is the Portuguese Golden Visa

Options for Wealthy Nigerians

Nigerians are increasingly looking for additional options when it comes to global travel and relocation. The most popular options are the citizenship by investment (CBI) programs - the Caribbean primarily. Here, foreign nationals can legally obtain a second citizenship and

US taxes set to rise

With the Democrats now controlling Congress and the Presidency, the new Biden Administration is set to fundamentally change the nature of tax. How this will impact Americans and business remains an open question. What is certain is the fact that

US ends UBO privacy

As this year's US defence appropriations act demonstrates, there seems to be a growing international trend on the part of governments to create a baseline in terms of disclosure of beneficial ownership. How a new Biden-Harris administration will act in

Closure of Cyprus CIP “a Great Travesty”

Very nice to be featured in IMI Daily's "Ten On The Weekend".

UK wealth tax

With all due respect to the BBC, the imposition of such a "one-time" wealth tax would have a disastrous impact on the British economy. Capital flight would occur, much like what is happening already in Argentina (which brought in such

Argentina and taxes

Argentinians normally look to Uruguay and then the United States when thinking about tax planning. Those routes seem now insufficient, given the political shift. Arguably, Latin Americans, and even North Americans, with means should now consider wealth planning options that

UK starts to tax wealth

Like other major economies in 2020, the UK is facing a tax deficiency in light of covid-19 and the severe contraction of its economy. Governments are now looking to new tax revenue schemes and everything is on the table. The

India introduces citizenship based taxation

Like others governments facing revenue shortfalls, India has just recently introduced citizenship-based taxation. Henceforth, Indian nationals, irrespective of physical presence in India, will be deemed to be tax residents in certain circumstances. Although India is still quite flexible in terms

Portugal to allow birthright citizenship

A very nice development in Portugal this week. Birthright citizenship will be henceforth allowed for those that are born in Portugal to parents that have been permanent residency for at least one year. Coupled with the country's Golden Visa Program,

Real Estate Collapse in Cyprus

As of November 1st, Cyprus will suspend its existing citizenship by investment programme. Although the benefits of such a programme are beyond question - FDI into the local economy and providing an opportunity for people and their families - the

Structural impediments to the Cyprus economy

Very nice to have my article featured in IMI Daily. My supposition is that the Cypriot economy cannot be so heavily real property focused, as it leads to not only stratification of wealth but also over exposure to a single

Global Real Estate Collapse

It seems that many in the financial industry are starting to push the notion that somehow the pending global real estate correction will be limited in scope. In my opinion, this is a dangerous fallacy. Misguided governmental response to Covid-19

“Neither fair nor helpful” – Thoughts on Al Jazeera’s investigation

IMI Daily today requested my feedback to the Al Jazeera investigation of the Cyprus citizenship-by-investment program and related corruption. Although there have been significant problems in the past, today the Cyprus CIP is one of the most onerous and well

Tax their obscene wealth.

With the Democrats now solidifying around a Biden-Harris ticket, the U.S. faces a real choice. Continue with the Trump-Pence paradigm or reject it in favour of something just as earth shattering. Never has politics been so polarising and the World

COIVD-19 and the pending collapse of real estate

Arguably, COVID-19 will be a world-wide tipping point for the ushering in of a more restrictive global system, flying in the face of unabated free trade that is predicated on the mobility of goods, services and labour. How this plays

How COVID-19 will change the World Economy and CBI Programmes

Epidemics are related to population mobility. COVID-19 is special in that today’s global economy is intrinsically linked to unprecedentedly prevalent and frequent population mobility. Today, a virus can spread unabated. Free-traders have always argued that the global circulation of goods,

Cyprus amends naturalization program

The Republic of Cyprus has recently amended its Naturalization by Exception Programme. The changes become effective as of 15 May 2019. Highlights include: A minimum investment of € 2.5m +VAT, compared to € 2m + VAT with current status under

Some thoughts on Austria

Austria's Ministry of Finance has recently provided some guidance on the question of an Austrian home office as it applies to an Austrian tax resident employee and whether such a setup can qualify as an Austrian permanent establishment for a

Dividends in Austria

The Austrian tax court has recently opined on the question of dividend payments from Austria to an intermediate EU holding company which has no substance (while its EU parent does). Generally in Austria dividends paid out by Austrian corporations trigger

Hungary vs. Google

On 12 September 2019, the advocate general of the European Court of Justice held that Hungary's advertisement tax legislation based on which Google was fined HUF 1 billion (approx. EUR 3 million) constitutes an unjustifiable restriction on the freedom to

Bulgarian Transfer Pricing

On 31 July 2019, Bulgaria's parliament adopted new transfer pricing rules in line with recommendations of the OECD. The new rules set out obligations for Bulgarian companies, Bulgarian permanent establishments of non-resident foreign companies and locally registered sole trades to

Czech Cross-Border Disclosure

Recently, the Czech government submitted to parliament a bill implementing DAC 6 on the mandatory disclosure of cross-border tax arrangements. The bill underwent several changes in comparison with the initial draft published in March 2019. DAC 6 - the EU

Bulgaria starts again with GDPR

Towards the end of January 2019, Bulgaria's legislature adopted the EU's GDPR regulation, but was subsequently overruled by the Bulgarian President. The President exercised his veto right on the grounds that the legislation did not go far enough to address

Amendments to the Hungarian Labour Code

Hungary has recently amended its labour code in order to increase permissible overtime levels. On an annual basis, permissible overtime has increased from 250 hours per year to 400 hours per year. Such overtime overrides any collective labour agreements in

Albania tax update

On 1 January 2019, Albania's Income Tax Act was amended with respect to imposition of new rules on the indirect transfer of ownership of assets situated in Albania. The new rules deal with the taxation of gains arising from such

Serbia institutes UBO registry

As of the close of 2018, Serbia has now established its central register of ultimate beneficial owners. Henceforth, Serbian companies, institutions, as well as branches and representative offices established by foreign investors in Serbia are required to register their UBOs

Austria changes its Data Protection

In early November, the Austrian Data Protection Authority issued a directive that data processing operations in all cases requires a data protection impact assessment (DPIA). Under Europe's new General Data Protection Regulation (GDPR), DPIA is required during data collection. The

Romania changes insolvency laws

Just this past October, Government Emergency Ordinance GEO 8/2018 was published, which set out certain new amendments to Romania's insolvency regime. The ordinance amends: (i) Law no. 85/2014, regarding Romania's insolvency law itself; (ii) ordinance no. 2/2000 regarding judicial application;

ESMA updates AIF disclosure requirements

On October 4, 2018, ESMA (the European Securities and Markets Authority) updated its view on the applicability Directive 2011/61/EU on alternative investment fund managers (AIFMs). The update provides guidance with respect to the cross-border management of alternative investment funds (AIFs), which have an umbrella

Germany moves to regulate online retailers. CEE providers beware.

Recently in August, Germany moved forward with a proposal directed against VAT avoidance relating to supplies of goods with a German nexus over online marketplaces. The bills expected to pass parliament in late fall and become effective as of January

US expands restraints on transfer of sensitive good and technologies

With concerns over challenges posed by China, the US government recently introduced new measures designed to enact control over the transfer and use of US goods and technologies both in the US and abroad. Applicable to emerging market M&A and

New Collective Agreements in Slovenia

Just this past August, Slovenia introduced a new collective agreement baseline for companies. The new collective agreement regulates business times for employers - specifically, it prohibits the scheduling of work on public holidays and bank holidays. With respect to weekends,

Monitoring Polish employees after GDPR

In the wake of GDPR, Poland has adopted a number of measures related to employee monitoring. Enshrined in the Polish Labor Code, there are a number of issues one should be aware of now when carrying on business in Poland.

Bulgaria adopts changes to Public Procurement

Bulgaria has recently adopted new appeal procedures related to public procurement. Designed to speed-up appeals and to bring an end to bad faith actions, the new rules are designed to place Bulgaria in line with more general European norms. Public

Croatia changes its capital markets regime

This past July, Croatia's parliament adopted a new Capital Markets Act in order to align Croatian legislation with the EU acquis. The at meets the EU's cornerstone financial markets regulation - the Directive on Markets in Financial Instruments repealing Directive 2004/39/EC

Russia moves forward on countermeasures

Russia has slowly moved forward in terms of its response to a recent push by the US to levy sanctions in April 2018 against certin Russian state-controlled entities and individuals, and the companies they control. Last month, legislation was passed

EU affects cross-border transactions

The EU has introduced new cross-border transaction reporting requirements. Recently in May, the EU quietly adopted Council Directive 2018/822/EU on the reporting of "potentially aggressive" cross-border tax-planning arrangements. Reporting requirements will kick-in on August 31st, 2020, after the Council Directive

US puts WTO into crisis mode

The US has put the WTO Appellate Body into crisis mode. Since the advent of the Trump administration, the US has consistently blocked appointments and reappointments to the WTO Appellate Body. As a result, the appellate body has now shrunk to

Hungary proposes screening of FDI

The Hungarian government has recently proposed legislative changes designed to enable regulatory screening of foreign acquisitions of certain Hungarian companies. Designed to protect strategic businesses, the proposed changes would include oversight of certain services (such as finance and telecoms) and

Major changes to Romania’s Public Procurement Regime

Quite recently, a Romanian government emergency ordinance regarding certain amendments to Romania's public procurement regime ("GEO 45/2018") has been approved and gazetted. Essentially, GEO 45/2018 amended and supplemented four laws and two government emergency ordinances as follows: Law no. 98/2016

Serbia to institute UBO law

The Serbian parliament has recently adopted a new law regarding the introduction of a central registry of ultimate beneficial owners (UBOs). In force as of June 8th, the UBO law stipulates that entities and their authorized persons conducting business in

European Commission legislative update

On May 24th, the EC published proposals related to the promotion of the use of small and medium sized enterprise (SME) growth markets. The proposals are designed to give more flexibility for SME growth market operators as to whether they

Poland introduces debtor registry

Poland has recently introduced another public registry related to debtors. Poland is in the process of introducing the Register of Public Law Dues, which is desiged to provide information related to any financial liabilities of an individual or corporate entity.

Bulgaria introduces GDPR

Bulgaria is set to introduce certain changes to the application of the EU General Data Protection Regulation (GDPR). Bulgaria's government has announced that it will legislate additional protocols to that exisitng under GDPR. Areas to be effected include employment, the

Cyprus adopts EU exchange of tax information

Cyprus has brought its domestic law inline with EU directive on mandatory automatic exchange of tax information. Cyprus has recently introduced Law 33(I)/2018 in furtherance of EU Directive 2016/881/EU. The changes concern EU wide administrative cooperation in the field of

US customer due diligence regime goes live

US banks have begun applying the US Treasury's new customer due diligence regime, requiring them to verify the identities of new business customers' beneficial owners, and report them to law enforcement agencies. The rules were finalised two years ago, under

Oil and gas industry strengthens

As the oil and gas industry strengthens with eyes on rising commodity prices, costs and emerging technologies, there are certain trends developing for 2018 that the industry should also keep in mind. Will 2018 be the year for the digital

Greece amends cadastral system

Greece has abolished and replaced its “National Cadastre and Mapping Agency S.A.” with a new public entity entitled the "Hellenic Cadastre" (“Elliniko Ktimatologio”). The new agency shall be based in Athens and is supervised by the Minister of Environment and

M&A in Cyprus

When it comes to M&A in Cyprus, there are a number of major laws one should be aware of, as follows: 1. Companies Law Cap. 113 (a) Sections 198-201 of Companies Law regulate mergers, divisions, partial divisions, transfers of assets

A short discussion on the electricity and gas sector in Albania

Albania performs reasonably well overall with respect to the quality of its energy (electricity and natural gas) sector. A recent EBRD energy law reform assessment, for example, shows that the country's regulatory independence remains strong although private sector participation and

Republic Srpska Tax Update

The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With

Belarus Tax Note

A draft law that would amend the Tax Code of the Republic of Belarus has been posted on the website of the Belarusian Ministry of Finance (the “Draft Law”). This time the draft has been published long before the start

New amendment to the Hungarian Civil Code

The purpose of the new amendment to the Hungarian Civil Code, effective as of 1 October 2016, is to make effective the independent mortgage, which was used under the former civil code, along with refining rules with respect to the

How Brexit may impact British property owners in Bulgaria

One of the most popular enquiries after Brexit is how expats and people who own property in Bulgaria will be affected. There are approximately 1.3 million UK citizens living in Europe many of which chose Bulgaria for their second home

The New Enforcement and Security Act in Serbia

Serbia’s new Enforcement and Security Act (ESA) was adopted on 18 December 2015, and has become effective as of 1 July 2016. The most relevant new rules are: the provision of new mechanisms to ensure effective enforcement; new competence of

How to establish a limited liability company in Czech Republic

A limited liability company is the most common corporate form established by foreign investors in Czech Republic. The activity is governed by a Memorandum of Association, which is signed by all shareholders. It is essential to note that it is

The Bulgarian Supreme Court has repealed cumbersome fee rates under the Public Procurement Act

Pursuant to a judgement dated 29 February 2016, the Bulgarian Supreme Court repealed Regulation no 196 of the Council of Ministers of 10 July 2014 with respect to the approval of the fee rates applicable to proceedings under Chapter Eleven

Cyprus: Proposed amendment in regards to automatic exchange of information

An important amendment to the Assessment and Collection of Taxes Law (N.4/1978) in Cyprus is currently under consideration by the Council of Ministers regarding automatic exchange of information. More specifically, the proposed amendment aims at regulating the conditions under which

Banking Secrecy in Cyprus

Complete bank secrecy is fast becoming a matter of the past. The Automatic Exchange of Information (AEOI) portal provides a comprehensive overview of the work the OECD and the Global Forum on Transparency and Exchange of Information for Tax Purposes

Brexit – Potential impact on London based private equity managers

On the 23rd of June, the UK voted to leave the European Union. Known as “Brexit”, the UK Government with now initiate Article 50 of the Lisbon Treaty, starting the two year procedure leading to the UK’s eventual withdrawal from

Slovenia amends insolvency law

Slovenia has amended the Financial Operations, Insolvency Proceedings and Compulsory Dissolution Act, which follow on amendments in 2013, amending preventive restructuring, simplified compulsory settlement and personal bankruptcy proceedings. Amendments to Slovenia's Insolvency Act, which were adopted by the National Assembly on

HNWIs seeking to leave the…

July 19, 2022

An interesting read from Family Capital. Although I agree with the net-outflow thesis, the issue is where will these millionaires...

Read More Tax and Wealth Management, Western Europe

Hungary blocks global minimum tax

June 20, 2022

Hungary blocked an EU directive that would impose a 15% minimum tax on multinational corporations, arguing the levy would deal...

Read More Hungary, Tax and Wealth Management

HNWIs seeking to leave the UK

Hungary blocks global minimum tax

Why Malaysia’s failure on MM2H will result in decreased FDI interest

When Investment Migration Programs Go Wrong.

The Pending Paradigm Shift

Wealthy beware

For the 99.5% Act

US attempts to create a global tax baseline

Cyprus changes permanent residency program to reflect fund options

Crypto & Taxes

FATCA and Foreign Bank Accounts

NY Beware. Americans are looking elsewhere.

Democrats push for a ‘Wealth Tax’

Rich Indians are set to leave

Options for Wealthy Nigerians

US taxes set to rise

US ends UBO privacy

Closure of Cyprus CIP “a Great Travesty”

UK wealth tax

Argentina and taxes

UK starts to tax wealth

India introduces citizenship based taxation

Portugal to allow birthright citizenship

Real Estate Collapse in Cyprus

Structural impediments to the Cyprus economy

Global Real Estate Collapse

“Neither fair nor helpful” – Thoughts on Al Jazeera’s investigation

Tax their obscene wealth.

COIVD-19 and the pending collapse of real estate

How COVID-19 will change the World Economy and CBI Programmes

Cyprus amends naturalization program

Some thoughts on Austria

Dividends in Austria

Hungary vs. Google

Bulgarian Transfer Pricing

Czech Cross-Border Disclosure

Bulgaria starts again with GDPR

Amendments to the Hungarian Labour Code

Albania tax update

Serbia institutes UBO registry

Austria changes its Data Protection

Romania changes insolvency laws

ESMA updates AIF disclosure requirements

Germany moves to regulate online retailers. CEE providers beware.

US expands restraints on transfer of sensitive good and technologies

New Collective Agreements in Slovenia

Monitoring Polish employees after GDPR

Bulgaria adopts changes to Public Procurement

Croatia changes its capital markets regime

Russia moves forward on countermeasures

EU affects cross-border transactions

US puts WTO into crisis mode

Hungary proposes screening of FDI

Major changes to Romania’s Public Procurement Regime

Serbia to institute UBO law

European Commission legislative update

Poland introduces debtor registry

Bulgaria introduces GDPR

Cyprus adopts EU exchange of tax information

US customer due diligence regime goes live

Oil and gas industry strengthens

Greece amends cadastral system

M&A in Cyprus

A short discussion on the electricity and gas sector in Albania

Republic Srpska Tax Update

Belarus Tax Note

New amendment to the Hungarian Civil Code

How Brexit may impact British property owners in Bulgaria

The New Enforcement and Security Act in Serbia

How to establish a limited liability company in Czech Republic

The Bulgarian Supreme Court has repealed cumbersome fee rates under the Public Procurement Act

Cyprus: Proposed amendment in regards to automatic exchange of information

Banking Secrecy in Cyprus

Brexit – Potential impact on London based private equity managers

Slovenia amends insolvency law

HNWIs seeking to leave the…

Hungary blocks global minimum tax

Why Malaysia’s failure on MM2H…

When Investment Migration Programs Go…

The Pending Paradigm Shift