Category: Tax treaties

Pagcor: Government not inclined to impose higher taxes on POGOs

State-run Philippine Amusement and Gaming Corp. expressed optimism the government will not impose higher taxes on offshore gaming operators in the country to encourage them to stay here. Pagcor chairman and chief executive Andrea Domingo said at the sidelines of the opening of the first Philippine-Asian Gaming Expo held on… – Continue reading

Pakistan money in Swiss banks dwindling for last three years

LONDON: Money kept by Pakistani nationals and enterprises in Swiss banks fell by 33 per cent to a record low of CHF380 million (Rs63 billion) in 2018, falling below the level of Indian funds for the first time in four years, Swiss National Bank’s (SNB) annual statistics report showed on… – Continue reading

Tax on reserve to hit cos’ business expansion: ICAB

The imposition of 15 per cent tax on reserve and retained earnings of listed companies will reduce capital and expansion scope of the companies, said the Institute of Chartered Accountants of Bangladesh on Saturday. The ICAB made the statement in its post-budget review. Finance minister AHM Mustafa Kamal placed the… – Continue reading

India ratifies multilateral convention to curb abuse of tax treaties

The union cabinet, chaired by Prime Minister Narendra Modi on Wednesday approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The Convention will modify India’s treaties in order to curb revenue loss through treaty abuse and base erosion… – Continue reading

Luxembourg: Tax Dispute Resolution Mechanism

The Bill of Law 7431 (“Bill”) introduced by the Luxembourg government on 11 April 2019 implements the European Union (“EU”) Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU (the “Directive”). The Directive meets the BEPS Action Plan 14 minimum standards and is a subsidiary… – Continue reading

India: Split Residency – ITAT Upholds The Taxpayer’s Claim For Treaty Exemption, Applies Centre Of Vital Interest Test

Dual Residency gets attracted when an expat in the year of move qualifies as a resident of the host country (i.e., the country in which he is deputed) as well as home country (i.e., the country of his residence). On account of dual residency, an expat can be doubly taxed… – Continue reading

India: Bombay High Court Quashes 197 Order Rejecting Mauritius Tax Treaty Benefits

High Court sets aside section 197 order due to absence of prima facie evidence of tax avoidance Rejects factors such as lack of business activities and administrative expenses as conclusive of sham transactions Holds that a detailed inquiry can be conducted during normal assessment Directs refund of withheld tax subject… – Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading

Delving into Hong Kong’s New Transfer Pricing Landscape

On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill).  This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading

Revised tax treaties usher in a new era in investment, taxation

Policy tweaks  curb evasion,  show  India  can woo investments without  sops Singapore, another major FDI contributor to India, too, enjoyed the same tax sops under a similar treaty with India NEW DELHI: For about a decade-and-a-half, revenue authorities examining foreign investment proposals received by the erstwhile Foreign Investment Promotion Board… – Continue reading

NBR for 30pc job quota for Bangladeshis

The National Board of Revenue recommended that the proposed guidelines on local entrepreneurs’ overseas investment should include provisions that the interested businesses have no overdue taxes in Bangladesh and have to employ minimum 30 per cent Bangladeshis in overseas projects. The NBR made the suggestions in its observations sent last… – Continue reading

Pakistan, Bulgaria sign double taxation treaty

ISLAMABAD: Pakistan and Bulgaria on Tuesday signed an agreement to get rid of double taxation and cooperate in preventing tax evasion as a state delegation from the European Union member country concluded its two days visit. The Federal Board of Revenue (FBR) Director General and Deputy Minister of Economy Bulgaria… – Continue reading

Cyprus and Kazakhstan sign Double Taxation Convention

The Republic of Cyprus and Kazakhstan signed on Wednesday a Convention for the Avoidance of Double Taxation and for the combating of Tax Evasion with respect to taxes on income. According to a press release issued by the Public Information Office, the Convention was signed in Nursultan, Kazakhstan, by the… – Continue reading

FIRS Vows to Eliminate Multiple Taxation

Obinna Chima The Executive Chairman, Federal Inland Revenue Service (FIRS), Mr. Babatunde Fowler, has restated the agency’s commitment to eliminating multiple taxation in the country. Fowler said this at a tax breakfast seminar with the theme: “Tax Controversy and Dispute Resolution,’ organised by KPMG Nigeria in Lagos, recently. According to… – Continue reading

Kuwait, Iraq ink several cooperation agreements

KUWAIT: The Kuwaiti-Iraqi joint committee held its seventh session in Kuwait on Sunday under the chairmanship of Deputy Prime Minister and Minister of Foreign Affairs Sheikh Sabah Al-Khaled Al-Hamad Al-Sabah and Iraqi Foreign Minister Dr Mohammad Ali Al-Hakim. The session resulted in the signing of a number of agreements, memorandums… – Continue reading

Mauritius: blue skies, sunshine – and these noteworthy changes to its domestic laws

Not just the ultimate holiday stop, Mauritius is also a preferred jurisdiction for fund managers looking to establish African-focused funds, say Michael Denenga and Nicole Paige, partners at Webber Wentzel. “A scenic island off the coast of Africa, Mauritius’ main competitive advantage is its proximity to the jurisdictions that African-focused… – Continue reading

Joint tax mechanism to enhance trade & investment among BRI countries

A new mechanism aimed at creating a more favorable tax environment for enterprises and countries involved in China’s Belt and Road Initiative (BRI) has been established. Tax officials and experts from dozens of countries and international organizations have gathered in China from April 18 to 20 for the first Belt… – Continue reading

HMRC targets accountants over tax evading clients

HMRC sent 1,414 requests to professional services firms demanding confidential information on clients suspected of tax evasion in the 12 months to 31 March 2018, according to law firm RPC. The production orders are issued by HMRC’s Criminal Investigation Directorate to force third parties, such as accountants, lawyers and other… – Continue reading

Foreign income declaration mandatory

KARACHI: The income tax law has made it mandatory for taxpayers to declare foreign income and assets in order to avoid penalty, Vishno Raja Qavi, former chief tax policy, Federal Board of Revenue (FBR), said on Thursday. He was highlighting the key points of Automatic Exchange of Information (AEOI) at… – Continue reading

Steven Gerrard sues HSBC for £100m over tax schemes

Rangers manager Steven Gerrard is taking legal action against his wealth manager following a crack down on tax avoidance schemes. The former Liverpool captain is among hundreds of investors who have launched a £100m lawsuit against HSBC’s private banking division, claiming it defrauded them, The Times has reported. Composer Lord… – Continue reading

Ukraine, Switzerland sign protocol on avoidance of double taxation

Ukraine and Switzerland have signed a protocol on the introduction of amendments to the convention on the avoidance of double taxation with respect to taxes on income and capital, and its protocol, concluded in Kyiv on October 30, 2000. Ukrainian Finance Minister Oksana Markarova and newly appointed Swiss President Ueli… – Continue reading

Angola’s parliament approves elimination of double taxation with Portugal, China and UAE

The Angolan parliament unanimously approved proposals for the resolution of agreements for the elimination of double taxation and prevention of tax evasion on income tax with Portugal, China and the United Arab Emirates (UAE), according to official information. The Secretary of State for Cooperation, Domingos Vieira Lopes, said that the… – Continue reading

Portugal: Portuguese Golden Visa – Investment Route And The Non-Habitual Residents Regime

Background Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe. Portugal is increasingly recognised as an international hub with 71 Double Taxation… – Continue reading

End of double taxation between Angola and Portugal approved in Lisbon

The Portuguese Parliament voted in favour of a proposed government resolution approving the agreement to eliminate double taxation with Angola, the Portuguese press reported on Friday. The parliament unanimously approved an agreement between Portugal and Angola on mutual administrative assistance and co-operation in fiscal matters signed in Luanda on 18… – Continue reading