Category: Double Tax Treaty

China’s Hong Kong signs tax pact with Finland

HONG KONG, May 24 (Xinhua) — The government of China’s Hong Kong Special Administrative Region (HKSAR) on Thursday signed a comprehensive avoidance of double taxation agreement (CDTA) with Finland, further expanding the HKSAR’s tax treaty network. The HKSAR government’s Secretary for Financial Services and the Treasury James Lau and Consul-General...

Jubilant Food Works Limited is not a PE of Domino’s Pizza International Franchising Inc: ITAT [Read Order]

In DCIT vs. M/s. Dominos Pizza International Franchising Inc., the Mumbai Bench of the Income Tax Appellate Tribunal ( ITAT ) held that Jubilant Food Works Limited, who holds the Master Franchise for Domino’s Pizza in India is not a Permanent Establishment of the Domino’s Pizza International Franchising Inc. In...

Ghana Parliamentary Minority raises red flag over Double Taxation Agreements with four countries

The Minority in Parliament has raised concerns over government’s intention to approve Double Taxation Agreements with the Czech Republic, Morocco, Mauritius and Singapore which they claim were not in the interest of the country. According to the Minority, Ghana would not benefit from the deal since the level of investments...

Taiwan wealth management update

There have been a number of recent legal and regulatory changes in Taiwan that have impact from a wealth management perspective. Tax Rates Changes effective 2018 Effective 1 January 2018, the new tax rates for Taiwan are: Local foundation tax rule tightened Effective 1 January 2018, dividend for local foundations...

Analysis: The double taxation treaty (DTT), a case of Nigeria and Singapore

President Muhammadu Buhari move to halt tax evasion signs an agreement with Singapore President Muhammadu Buhari, on Monday 26 March 2018, signed the instrument of ratification of agreement with Singapore against double taxation and fiscal evasion. The President’s assent is pursuant to the approval of the double taxation treaty (DTT)...

Zimbabwe, Qatar to pursue investment protection, taxation agreements

HARARE, May 7 (Xinhua) — Zimbabwe and Qatar on Monday agreed to expeditiously negotiate and conclude agreements that protect future investments and avoid double taxation, Finance and Economic Development Minister Patrick Chinamasa has said. Addressing journalists in Doha, Qatar, after the first meeting between Zimbabwean President Emmerson Mnangagwa and Amir...

UK Revisits Proposed BEPS Changes To Its Double Tax Treaties

The UK tax agency, HM Revenue and Customs, on April 16, 2018, released proposed changes to the list of amendments it intends to make to its bilateral double tax avoidance agreements through the OECD’s base erosion and profit shifting multilateral instrument. The new document – Proposed changes to the provisional...

Seychelles Needs To Redouble BEPS Efforts: UN Expert

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in...

India Adds BEPS Provisions To Qatar Tax Treaty

India has approved amendments to its double tax agreement with Qatar. The amendments update the information exchange provisions between the two countries in line with current international standards. A new Limitation on Benefits (LOB) provision has been introduced, which is designed to prevent “treaty shopping” (whereby companies or transactions are...

Professional Fee paid by Deloitte India to Its US and Singapore Entities Not Taxable in India, No TDS: ITAT [Read Order]

Granting tax relief to Deloitte India, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) held that the provisions relating to Tax deduction at Source (TDS) are not applicable to the professional fee paid by them to its Group Entities in US and Singapore. The division bench of the...

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying...

India-Iran DTAA – A Step Forward in India’s Economic Engagement with Central Asia

India and Iran signed a Double Taxation Avoidance Agreement (DTAA) in February, during Iranian President Hassan Rouhani’s official visit to India. The ‘Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income’ aims to encourage the movement of investments and services...

High net worth expats in UAE increasingly applying for second passport

High net worth residents in the UAE are increasingly applying for second passports to avail of maximum visa-free travel opportunities, expand businesses and avoid double taxation, experts have said. According to companies involved in citizenship programmes, most of the demand for second citizenship programmes is coming from Indians, Pakistanis, Syrians...

Singapore Updates Guidance On Transfer Pricing Regime

The Inland Revenue Authority of Singapore (IRAS) on February 23, 2018, released the fifth edition of its Transfer Pricing Guidelines for income tax. During a public consultation held in June 2017, stakeholders asked the Ministry of Finance to provide more clarity and guidance on transfer pricing documentation (TPD) requirements, specifically...

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...

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...