Category: Tax treaties

Kosovo, Switzerland sign agreement on double taxation

Kosovo and Switzerland signed on Friday an agreement regulating taxation of income and capital, which is beneficial for both countries, the Swiss federal government said. Under the agreement on double taxation dividends will be taxed at source at a maximum rate of 15%, while qualified participations – at no more...

FPI holdings from Singapore, Mauritius surge 25% before DTAA implementation

Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two...

Data leak reveals details of 70,000 offshore firms in Malta, German state minister claims

Malta denies claims A data leak has revealed information about 70,000 offshore companies in Malta, a German state minister claimed this morning. North Rhine-Westphalia finance minister Norbert Walter-Borjans said the data also included information about several German corporations and up to 2,000 German taxpayers. Tax authorities in the city of...

Cyprus and Luxembourg object to a proposed EU common corporate tax base directive

Cyprus and Luxembourg, two of the EU`s financial centres, on Monday cautioned against the implementation of the proposed Common Consolidated Corporate Tax Base (CCTB) in the European Union. “Cyprus believes that we should be very cautious and very careful when it comes to corporate taxation,” Cypriot Finance Minister Harris Georgiades...

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax...

Tax residency certificate is vital for claiming relief under DTAA

Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential...

UAE inks multilateral tax co-operation convention

The United Arab Emirates (UAE) has signed an international tax agreement – Multilateral Convention on Mutual Administrative Assistance in Tax Matters(MAC), which is now seen as the ‘gold standard’ for co-operation in tax administration. With this move, UAE has become the 109th jurisdiction to join the most powerful multilateral treaty...

Ukraine Ratifies Tax Treaty With Malta

On April 13, 2017, the Ukrainian Parliament ratified its tax treaty with Malta, which provides for lower withholding tax rates on dividends, interest, and royalties. Under the deal, the withholding tax rate for dividends would be capped at 15 percent. A special rate of five percent would apply to dividends...

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they...

EU Sets Sights on Tax Privileges in Special Economic Zones

The European Commission wants stricter guidelines for the “tax privileges’’ some European Union countries permit within special economic zones in their jurisdictions, to enhance economic development. The confidential proposal for the guidelines, seen by Bloomberg BNA, is currently under discussion within the EU’s Code of Conduct Group for Business Taxation,...

Corporate giants hit with $2.2b Australia tax bill

Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the...

China’s New Transfer Pricing Rules Keep Arm’s-Length Approach

China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the...

Hong Kong signs agreements with Portugal and South Africa on automatic exchange of financial account information in tax matters

Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI), a Government spokesman said today (April 3). “We have been seeking to expand Hong Kong’s AEOI network with our tax treaty partners. The signing of agreements with Portugal...

New Chinese tax rule to take aim at multinationals’ profit shifting

Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website...

Brazil’s Petrobras Loses Appeal of Double Taxation

For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although...

Focus BEPS Work on Practical Results, Not Participation: Stack

The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of...

OECD, IMF Reports On Providing Businesses With Tax Certainty

The OECD and the International Monetary Fund have submitted to the Group of Twenty (G-20) nations a report on improving tax certainty for businesses. The report follows a global survey of more than 700 large, multinational businesses and a survey of 25 advanced nation tax administrations. The report highlights several...

Recourse to MAP and bilateral APA rollback available under revised tax treaty: PwC

MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning...

Hong Kong Agrees Automatic Exchange Of Information With Six New Jurisdictions

Hong Kong has signed agreements with six jurisdictions to automatically exchange financial account information in tax matters. The agreements expand Hong Kong’s Automatic Exchange Of Information (AEOI) network to include Belgium, Canada, Guernsey, Italy, Mexico, and the Netherlands. These countries join Japan, Korea, and the UK as “reportable jurisdictions” for...

GAAR & POEM- Combating Tax Avoidance

The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be...

Pakistan, Switzerland to sign agreement for bank account information exchange: Dar

Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable...

Romania Joins BEPS Inclusive Framework

Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer...