Category: Double Tax Treaty

Parliament ratifies double tax agreement with Malaysia

The Verkhovna Rada of Ukraine ratified an agreement with Malaysia on the avoidance of double taxation and the prevention of tax evasion and the protocol thereto, adopting Bill No. 0002. 333 MPs voted in favor of it. It was broadcasted by official Rada Channel. The agreement extends to individual income… – Continue reading

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019.  ... - Continue reading

Armenia, Malta sign double tax treaty

YEREVAN, SEPTEMBER 25, ARMENPRESS. Armenian Foreign Minister Zohrab Mnatsakanyan on September 24 met with Malta’s Minister for Foreign Affairs and Trade Promotion Carmelo Abela on the sidelines of the 74th session of the UN General Assembly in New York, the Armenian ministry told Armenpress. The officials praised the current dynamic… – Continue reading

FATCA blamed for one in five US expats planning to give up passport

One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading

European Union: The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems

In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading

Govt launches crackdown on benami assets

ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading

Luxembourg: Luxembourg Government Submits Bill To Parliament Implementing The EU Anti-Tax Avoidance Directive 2 Into Domestic Law

Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

Gibraltar and UK Open Negotiations to Enter into a Double Tax Agreement

The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading

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

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

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

Double tax agreements come into force

Double taxation agreements with China, Brunei and Vietnam came into effect Tuesday with the New Year, with experts saying they will bolster trade and attract investment. The agreement with China on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed… – Continue reading

Worldwide: UK Tax Round Up – November 2018

General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill… – Continue reading

FBR urged to clarify taxability of foreign rental income

There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for… – Continue reading

NRIs don’t need to reveal details of foreign bank accounts, assets to Indian tax dept: I-T Tribunal

The Income-Tax Appellate Tribunal (ITAT) has said NRIs do not need to reveal details of their foreign bank accounts and assets to Indian authorities. The tribunal has also ruled that the onus is on the I-T Department to prove an assessee has parked undeclared income arising from India in foreign… – Continue reading

India-China amends double taxation avoidance treaty

New Delhi, Nov 26 India and China have amended the bilateral tax treaty which will help prevent tax evasion by allowing exchange of information, the Finance Ministry said Monday. The Government of India and the People’s Republic of China have signed a protocol on November 26, 2018, to amend the… – Continue reading

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading

Cyprus: Entry Into Force Of The Protocol Amending The Convention On The Avoidance Of Double Taxation Between Cyprus And Mauritius

The Cyprus Tax Department has announced that the procedures for ratification of the protocol dated 23 October 2017 amending the Convention on the Avoidance of Double Taxation between Cyprus and Mauritius have been completed, and the protocol entered into force on 2 May 2018. The protocol replaces text of article… – Continue reading

Kenya and Mozambique move to remove double taxation, ease Visa rules

Foreign Affairs Cabinet Secretary Monica Juma says the move is aimed at eliminating double taxation. Juma and her Mozambique counterpart Jose Antonio Pachecho have constituted a Joint Commission of Cooperation tasked with this mandate ahead of the State Visit by Mozambique President Filipe Nyusi who will be hosted by President… – Continue reading

Angolan president seeking increased cooperation with Portugal

Luanda, ANGOLA, November 18 – Angolan head of state Joao Lourenco has pledged to raise bilateral cooperation with Portugal during his visit to European country scheduled for 22- 24 November this year. Joao Lourenco made the pledge during an interview with the Portuguese newspaper “Expresso”, on the eve of his… – Continue reading

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… – Continue reading

European Union digital tax levy could be delayed until 2020

Arriving at the meeting Tuesday in Brussels, the Danish minister of Finance, Kristian Jensen, said of his side: “Everything is possible in politics but I think that it is very hard to reach an agreement on the taxation of the digital economy”. Under the proposal, a 3pc levy would be… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Tax Residency in China under New IIT Law: Impact on Foreigners

How tax residency in China gets determined is among key changes introduced in the recently passed individual income tax (IIT) law. The new law is set to reform IIT in the country, including the tax treatment of foreigners. Beginning January 1, 2019, an individual who resides in China for 183-days… – Continue reading

Govt to serve notices to 300 Pakistanis owning properties in UAE: sources

ISLAMABAD: The federal government has decided to issue notices to 300 Pakistani nationals who own properties in the United Arab Emirates, sources informed Geo News Saturday. The sources said that notices will be sent to individuals who own six or more properties in UAE. They will be inquired about their… – Continue reading

Withholding Taxes – What, why, when?

The tax regime in Sri Lanka historically imposes WHT on both domestic as well as cross border payments. WHT on domestic payments eases revenue collection (e.g.: PAYE) while WHT on cross border payments are adopted by most countries to ensure that the fair share of tax is retained in the… – Continue reading