Category: Tax treaties

Govt. of India and Govt. of NZ signs Third Protocol to the Convention for avoidance of double taxation and the prevention of fiscal evasion

The Ministry of Finance (Department of Revenue) vide notification S.O. 3512(E) dated November 2, 2017 sets out the Third Protocol to the Convention between the Government of the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with...

Cabinet Gives Nod To Signing Double Taxation Avoidance Agreement With Hong Kong

The Cabinet today gave its green light to an agreement between India and the Hong Kong Special Administrative Region (HKSAR) of China for avoiding double taxation and prevention of tax evasion. The Cabinet, chaired by Prime Minister Narendra Modi also approved the protocol amending the agreement between India and Kyrgyzstan...

Jersey, Guernsey and Isle of Man join commitment to tackle tax evasion

The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The...

Aircraft Leasing in Russia – Key developments in Russian tax and insurance laws

Summary: With effect from 1 January 2017, a number of amendments to Russian law have come into force which will affect aircraft leasing arrangements for lessors and financiers that have aircraft leased or financed with Russian operators. These amendments have started to affect negotiations and re-negotiations of leases with Russian...

Turkey: Turkey Updates Rules On Double Taxation Prevention Treaties For Independent Professional Services

Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the...

Japan’s National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which...

Bahamas Converts Finland Taxation Deal To Automatic

THE Bahamas yesterday upgraded its tax information exchange agreement with Finland to the automatic variety, as it bids to meet global standards by September 2018. K P Turnquest, deputy prime minister, signed the Protocol to Amend the Tax Information Exchange Agreement between the Bahamas and Finland, with the latter’s ambassador...

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding...

New Private Tax Ruling Clarifies the Conditions for New Immigrants to Obtain an Israeli Residency Certificate

Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not...

Inland Revenue Ordinance to be amended to facilitate international tax co-operation

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 5) Bill 2017 (Amendment Bill) was gazetted today (October 6). The Amendment Bill seeks to pave the way for Hong Kong’s participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and to align the Inland Revenue Ordinance (IRO)...

EU eyes corporate rules shake-up with law on seat transfer

The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for...

Hong Kong to examine tax concessions to attract global funds, Financial Secretary says

Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the...

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If...

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes...

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country...

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a...

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

Japan, Estonia Sign Double Tax Treaty

Japan and Estonia signed a convention to eliminate double taxation on cross-border trade and investment on August 30. The treaty sets out the taxing rights of both countries on cross-border income deriving from investment or trade between the two. It also provides for assistance in the collection of tax and...