Category: Tax treaties

Tax Planning for NRIs Returning to India

In general, investment and tax provisions relating to non-resident Indians (NRIs) returning to live in India are fairly generous. However, NRIs must carefully plan their return to India to ensure there are no surprises with respect to managing their overseas income and investments. In this article, we examine some of...

Applying for China’s DTA Benefits in Profit Repatriation

China’s double tax avoidance agreements (DTAs) can be used to avail lower tax rates while making outbound payments. However, DTA benefits are not automatically applicable to everyone. Foreign invested enterprises and their overseas headquarters must satisfy certain qualifications and go through relevant procedures to obtain the benefits. Beneficial owner assessment...

Cyprus: Approach Of Greek Authorities In Determining A Valid Foreign Proof Of Tax Residence

In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year...

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information...

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 1

1.Introduction Due to the influence of International Monetary Fund, the income tax law of Sri Lanka witnessed a near paradigm shift with the introduction of Inland Revenue Act No.24 of 2017 (new IRA) by repealing Inland Revenue Act No.10 of 2006 with effect from 1 April 2018. Unlike the Inland...

TAX MATTERS | THE TAXATION OF COMPANIES IN MACAU – WORLDWIDE OR TERRITORIAL BASIS? (CONT.)

Our previous article about the taxable basis for the taxation of companies in the Macau territory made reference to the fact that the courts in Macau, notably the Court of Second Instance (TSI) and the Tax Administration, do not seem to share the same view regarding income considered as the...

McDonald’s Luxembourg tax deal not illegal

BRUSSELS (Reuters) – McDonald’s tax deal with Luxembourg did not breach EU state aid rules, EU antitrust regulators ruled on Wednesday, saying the reason the US fast food chain did not pay some taxes was due to the mismatch between US and Luxembourg laws. The decision by the European Commission...

Chasing tax evaders worldwide

Indonesia is set to join the global treaty on the Automatic Exchange of Information (AEOI) on tax matters this month, and will then have virtually all the “high-caliber weapons” it needs to hunt down tax evaders — not just within the country but anywhere in the world, including tax-haven countries....

Panasonic to Move European Headquarters Out of UK as Brexit Concerns Grow

Several multi-national corporations have moved their European headquarters outside of the UK ahead of Brexit, and many others are expected to follow suit, especially as the likelihood of a no-deal Brexit rises further. Japanese tech giant Panasonic will be transferring its European HQ away from London to Amsterdam in October...

Automatic exchange of tax evaders data from September 1: FBR

ISLAMABAD: The Federal Board of Revenue (FBR) on Monday informed the task force constituted by the Prime Minister to repatriate laundered ill-gotten funds that newly installed computer software would ensure the automatic exchange of information about tax evaders with the Organisation for Economic Cooperation and Development (OECD) from September. The...

UK – GOVERNMENT PUBLISHES OFFICIAL GUIDANCE ON ENGAGING WITH UMBRELLA COMPANIES

The HMRC published an official guidance yesterday on engaging with umbrella companies in the UK. The guidance provides advice and spotlights umbrella companies that effectively operate tax avoidance schemes. “Most employment agencies and umbrella companies operate within the tax rules. However, some umbrella companies and agencies promote arrangements that claim...

Nigeria Concludes Double Tax Treaties With Ghana, Cameroon

The Federal Government of Nigeria (FGN) concluded the negotiation of Double Taxation Agreements (the DTAs) with the Republic of Ghana and the Republic of Cameroon on 26 July 2018 and 3 August 2018, respectively. While this is a welcomed development, it is expected that efforts will now be directed towards...

Sri Lanka And Oman Sign Agreement On Avoidance Of Double Taxation, Tax Evasion

An agreement on Avoidance of Double Taxation and Prevention of Fiscal Evasion between Sri Lanka and Oman was signed during the Second Meeting of the Sri Lanka-Oman Bilateral Consultations, held on August 15, 2018 in Colombo at senior officials’ level by the leaders of the respective delegations. The Sri Lankan...

Nigeria-Singapore income tax treaty to take effect Jan. 1

A bilateral double taxation agreement between Nigeria and Singapore generally is to take effect Jan. 1, 2019, although in Singapore, provisions regarding income taxes other than withholding taxes are to take effect Jan. 1, 2020. The treaty, also known as a DTA, is to affect how each country’s income tax...

VN-Cambodia agreement on double taxation avoidance ratified

The Government has ratified the agreement on double taxation avoidance and income tax evasion prevention between Vietnam and Cambodia. The Government assigned the Ministry of Finance to coordinate with relevant ministries and agencies of Vietnam and Cambodia in implementing the agreement. The agreement was officially signed on the occasion of...

Which Countries is The Cryptocurrency Taxed In?

The cryptocurrency industry is still at a very early stage of its development, so there are no single international rules yet. The governments of individual countries independently try to regulate digital assets. The tax on the cryptocurrency varies in different countries. Within the framework of this article, we will try...

Rs. 2,476 cr collected as Tax and Penalty under Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015, says MoS Shiv Pratap Shukla

The Government has collected Rs. 2,476 as Tax and Penalty under Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 said Minister of Finance for State Shiva Pratap Shukla in the Rajya Sabha. The Government of India has taken various steps for curbing the black money...

OECD to help Pakistan implement world tax standard

ISLAMABAD: The Organisation of Economic Cooperation and Development (OECD) on Friday announced that they launched new programme to support Pakistan in implementing new international tax standards. According to statement issued by the OECD after holding three days talks with Pakistani authorities stated that as part of a mission held from...