Category: Tax treaties

China’s Anti-tax Avoidance Rules

The general anti-avoidance rule was first introduced in China under the 2008 CIT Law. It empowers Chinese tax authorities to make reasonable adjustments where an enterprise implements an arrangement without reasonable business purposes in order to reduce its taxable income or profit. According to the CIT Law’s Implementation Guidelines, “an...

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime....

Kazakhstan ratifies amendments to double taxation convention with India

ASTANA. KAZINFORM Kazakhstan has ratified the Protocol between the Governments of Kazakhstan and India on introducing amendments to the Convention on the avoidance of double taxation, the press service of Akorda reports. Head of State Nursultan Nazarbayev signed the Law of the Republic of Kazakhstan “On Ratification of the Protocol...

Sherman Secures Treasury’s Commitment to Pursue U.S.-Armenia Double Tax Treaty

Secretary Mnuchin Commits During Congressional Testimony to Assign Treasury Department Officials to Work on Bilateral Accord WASHINGTON—Treasury Secretary Steven Mnuchin, during Congressional testimony Tuesday before the U.S. House Financial Services Committee, agreed – in response to direct questioning by Representative Brad Sherman (D-CA) – to commit Treasury Department officials to...

Israel set to adjust tax policies to counter Trump reform, tax chief says

Also, multinational companies with a physical presence in Israel will soon get their first tax bill Israel will need to amend its corporate tax policies to counter the effects of US President Donald Trump’s tax reform, the head of Israel’s Tax Authority head acknowledged — but only slightly. “There will...

Barbados, Jamaica Sign New International Tax Treaty

PARIS, France– Ministers and high-level officials from six countries, including two in the Caribbean, have signed the BEPS Multilateral Convention, the first multilateral treaty of its kind. The Convention will enable governments to swiftly update their networks of existing tax treaties and further reduce opportunities for tax avoidance. Barbados, Jamaica,...

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not...

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not...

Govt to announce amnesty for undeclared foreign assets ahead of OECD’s treaty

KARACHI: Government on Saturday said it may roll out an amnesty to allow offshore bank account holders to declare their wealth against nominal tax rates ahead of the implementation of OECD’s treaty to exchange financial details with foreign countries in September. Miftah Ismail, adviser to the Prime Minister for finance,...

Facebook, Google Under Scrutiny for Tax in Israel

Israel is assessing Alphabet Inc. subsidiary Google and Facebook Inc. on their operations in the country, Tax Authority Director General Moshe Asher told the Knesset parliament Jan. 8. “The internet giants and other companies right now are undergoing a very significant assessment procedure which in the end will yield from...

Transfer Pricing Dispute Resolutions in India: New Relaxations

The Income Tax Department recently released a clarification stating that it would accept requests for mutual agreement procedures (MAPs) and bilateral advance pricing agreements (BAPAs) in transfer pricing disputes with all countries regardless of the existence of specific provisions in the Double Taxation Avoidance Agreements (DTAAs). A 2012 survey by...

Taxation agreement with Singapore in effect

The double tax avoidance agreement (DTA) between Cambodia and Singapore came into effect this month, helping clarify taxation rights on all forms of income arising from cross-border business activities, while minimising double taxation. On January 1 the Inland Revenue Authority of Singapore (IRAS) issued an announcement stating that the DTA...

Taiwan Seeking US Double Tax Treaty

Taiwanese Premier Lai Ching-Te has directed the Ministry of Finance to work towards a Taiwan-US tax treaty. Speaking at a strategic briefing to the National Development Council on January 4, 2018, Lai noted that the US is one of Taiwan’s most important trading partners. A tax treaty would ensure that...

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended...

India Signs Three Further APAs During December

India entered into three more advance pricing agreements in December, with two unilateral agreements and a bilateral APA concluded with authorities in the United Kingdom. With the signing of these agreements, the total number of APAs entered into by the Central Board of Direct Taxes totals 189, comprising 173 unilateral...

US tax reform breaks global rules, EU says

European finance ministers are worried. They say the United States’ big tax reform bill contains measures that would unfairly disadvantage European business and contravene global fair-taxation rules. Are they right? Last week, the finance ministers of Europe’s five biggest economies — Germany, France, the UK, Spain and Italy — wrote...

Thousand billions in lost tax from foreign enterprises

Vietnam has lost thousands of billions of dong in taxes as foreign enterprises, especially large-scale ones, refuse to pay based on the Double Taxation Avoidance Agreement. Massive revenue without having to pay taxes The Ho Chi Minh City Department of Taxation has recently issued an ultimatum for Uber B.V Netherlands...

Bahamas Faces Major Tax, Exchange Control Shake-Up

The Bahamas may have to completely overhaul its corporate and taxation structure to escape European Union/OECD ‘blacklisting’ threats, the Attorney General revealed yesterday. Carl Bethel QC told Tribune Business that the Government was “looking very carefully” at whether compliance with European (EU) demands will require this nation to eliminate the...

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice...

OECD statistics show 20% increase in outstanding tax treaty disputes involving UK

The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the...

Ten important Canadian Tax compliance considerations for new Canadians

The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on...

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax...

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the...