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Collective Chinese
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At first glance the protocol is a simple case of updating the long-standing treaty and bringing certain definitions into line with the latest OECD double taxation treaty model. On the other hand it may be regarded as an attempt by Moscow to close what has hitherto been one on the most lucrative loopholes for Russian 9and other0 property speculators for many years.
Advantage: The new protocol includes the provision for the removal of Cyprus from the Russian blacklist. This means that dividends received by Russian companies from Cyprus subsidiaries will finally be able to qualify for the Russian dividend participation exemption. Subject to ratification, the protocol is expected to come into effect on 01/01/2010.
Changes:
- Withholding tax remains at 0% on interest and royalties.
- The maximum withholding tax rate of 10% is reduced to 5% (if the beneficial owner has directly invested the capital of the company paying dividends a minimum investment equivalent to EUR100,000 (from $100,000 USD).
Capital gains on immovable property
- Companies which hold more than 50% of their assets in Russian immovable property will be taxed in the country where the property is situated.
- However this does not include gains from the alienation of shares listed on an approved stock exchange or from a corporate reorganisation and further does not include gains derived from a pension fund, provident fund or from the governments of either the Russian Federation or Cyprus.
- This provision will not come into effect until 2014 thus allowing time to prepare mitigating the tax implications of this change subject to requests from clients.
Redefinition:
- 'Dividends' have been given a broader definition to include payments on shares of mutual investment funds or other similar collective investment vehicles and depository receipts for shares.
- 'Interest' now includes debt claims of any type (penalty charges for late payments or interest are classified as dividends).
Clarity:
- Where the 'effective management' of a person (other than an individual) cannot be determined: The competent authorities of the two countries will agree to reach a mutual decision on the matter at hand.
- The definition of 'Permanent Establishment' has been expanded to include the taxation of profits from services performed in one country by an entity of another country through an individual(s) present in the other country exceeding in aggregate 183 days in any 12 month period.
- Distributions from mutual investment funds are to be treated as dividends. This is a welcome change as dividends are subject to a maximum withholding tax of 10% whereas under current Russian law, distributions from mutual funds are subject to a 20% withholding tax.
Conclusion: The effects of the only major amendment being the capital gains tax amendment to be introduced in 2014 can be limited by seeking timely tax advice.
The treaty remains the most favourable double taxation treaty concluded with the Russian Federation and retains the attractive 5% withholding tax on dividends for investments equivalent to EUR100.000.
Susan Davies. YourBooks Ltd Accounting and Finance part of the Your Group of companies based in Cyprus (http://yourbooks.com.cy/).
The Fabulous Chinese Silver Commemorative Coins
If you're a coin collector and are particularly fond of brilliant, uncirculated silver coins then most likely you'll be inquisitive about Chinese Silver Commemorative Coins. These coins are usually minted for collection purposes as well as memorial pieces to honor of special events and people that have made a difference or a great impact in the country of China.
For example, to commemorate the Beijing Olympics, Chinese coins were made and designed just for that purpose. Other countries have also recognized the great thing about Chinese coins, particularly Australia, Somalia, Singapore, and the Isle of Man, so coinages were organized and different gold and silver coins are now circulating the markets today that contain the Chinese zodiac on one side and the partnering country's national symbol on the other.
These coins, depending on the weight, the design, and the dear metal content, can either be cheap ( RMB 3 to US $10-15) or pricey (usually over a hundred to one thousand dollars) because of its rarity and the history that go with it. If you have an interest in picking up Chinese Silver Commemorative Coins, you can find a lot of original pieces or series online in merchant internet sites like Amazon and Ebay.
If you're looking for those with the Chinese zodiac or the Giant panda in them, all you must do is just search through Google and Yahoo and you can be able to find the set or piece to finish or add to your collection. There's bound to be a seller or coin dealer that may have the coin or series you need to finish your personal collection.
If you're a seller of coins, you may also exploit this opportunity by selling your own set of Chinese silver and gold on the internet. Particularly if they are Chinese Silver Commemorative Coins, you are certain to be showered with all sorts of offers from coin enthusiasts all over the world.
About the Author
You can find great prices and selection on the fabulous Chinese Silver Commemorative Coins at: ==> ChineseSilverCoins.com
I have never dated my own race, ever...?
I have only been with 6 girls as of now... All Mexican and Hispanic. I never made a conscious effort to seek out or date women of my own race (Asians and Chinese). I used to be attracted to them in my high school days. But, after some bad experience in college, I totally write them off now. It seemed that they did not want to date men of their own race, so I just lost that attraction towards them. I met some nice and beautiful women of the Hispanic culture who seemed more sociable and less uppity compared to those young Asian women. I never looked back again. Yet, I still wonder am I missing out for never having dated a woman of my own race? Is it mentally healthy for me to totally write them all off as a collective group and view them as turncoats who spit at their own race and culture? I still prefer Hispanic women over them, but I want my justification to be legit and not hate-filled. There is a generation of young Asian men and women hating and avoiding each other.
First, there's nothing wrong with being attracted to one race more than the other....as long as its not based on prejudices or other biases.
Second, there are good and bad women in every race...just like there are good and bad in every race of men. I'm sorry you had such bad former experiences in the past, but it does happen to almost everyone sooner or later. Some worse than others, but everyone goes through it to some extent almost. Are you sure your past isn't what makes you see other Asian women as "uppity" or "less sociable"? I can't believe that ALL Asian women are those things. No race can be so broadly categorized as that and still be true. You met some Asian women who aren't very nice, but that doesn't mean all of them are not nice. I know many Asian women and almost all of them are married to Asian men and most of them are the nicest people you'd ever want to meet in this world.
So yes, you might be missing something....then again, you might not. If you truly prefer Hispanic and Mexican women without any grudges against Asian women, then so be it. Date those that make you happy. The one thing you might be missing out on though is another person who can understand where you're coming from, someone who understands your culture totally or who was most likely raised with similar beliefs as you were in your family.
My opinion? Date who you are most comfortable with, the ones that you get along with and think that you might be able to develop a long lasting relationship with. I also think that because you are asking this question, you will always wonder through your life if you made the right choice in choosing someone who is not Asian. Alleviate your fears. Date a few Asian women and see if there is something you can get from them that you can't with another race. And remember that even if the Asian women you knew were "uppity", people mature and change. There could be other reasons why these women treated you like they did....doesn't have to be about race.
China's Summer Of Labor Unrest
A deficit of workers' rights is destabilizing the manufacturing sector.
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