Category: Tax Authority

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

Tax treaty ratified

‘The new tax treaty between Australia and Israel will ensure the economic, trade and commercial relationship between our two countries is strengthened’. A “HISTORIC” new tax treaty between Australia and Israel has been hailed as “representing an important milestone in removing tax barriers and facilitating trade and investment” between the… – Continue reading

Dhaka, Prague sign deal to avoid double taxation

Bangladesh and the Czech Republic have signed a double taxation avoidance agreement (DTAA) in a bid to strengthen bilateral trade and investment ties between the two countries. National Board of Revenue (NBR) chairman Md Mosharraf Hossain Bhuiyan and Czech deputy prime minister and finance minister Alena Schillerova inked the agreement… – Continue reading

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise from avoidance, evasion or repeated insolvency and non-payment of tax debts or tax-related penalties of the company. ... - Continue reading

FBR asks UAE to share details of Pakistanis hiding behind Iqama status

Chairman Federal Board of Revenue (FBR) Shabbar Zaidi on Monday wrote letter to UAE authorities and asked for devising mechanism to share details of Pakistanis who are hiding behind Iqama based residential status to evade taxes. In a letter written to Ministry of Finance UAE by the Chairman FBR Shabbar… – Continue reading

EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to a Gibraltar companies from withholding tax

The Advocate General (AG) in an opinion issued 24 October (Case C-458/18) stated that a company incorporated in Gibraltar and subject to Gibraltar corporation tax cannot be considered to be a “company of a Member State” within the meaning of the parent-subsidiary directive (Directive 2011/96). ... - Continue reading

US IRS tells banks not to close accounts just because of missing tax ID number: FATCA

The US Internal Revenue Service has eased the rules of FATCA compliance by telling banks overseas that they are not required to close the accounts of their accidental Americans clients who have not provided their tax identification number by January 2020. FATCA was passed in 2010 and forces banks wanting… – Continue reading