Category: Double Tax Treaty

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

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… – Continue reading

Kazakhstan ratifies protocol amending double taxation avoidance deal with Uzbekistan

President of Kazakhstan Nursultan Nazarbayev has signed the law on ratification of the protocol between Kazakhstan and Uzbekistan on avoidance of double taxation of incomes, the press service of the head of state reported Sept. 18. “The head of state has signed the law of the Republic of Kazakhstan “On… – Continue reading

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… – Continue reading

Government approves double taxation avoidance pact with Macau

Hanoi (VNA) – The Government has approved an agreement between Vietnam and China’s Macau Special Administrative Region on the avoidance of double taxation and prevention of income tax evasion. The Government assigned the Ministry of Finance to chair and coordinate the two sides’ relevant agencies to implement the pact. The… – Continue reading

Receipts from Web Hosting Services to Indian Entities can’t be treated as FTS under Indo-US Tax Treaty: ITAT [Read Order]

The Mumbai bench of the Income Tax Appellate Tribunal ( ITAT ) has held that the income earned from the web hosting services cannot be treated as fee within the meaning of Article 12 of the Double Taxation Avoidance Agreement (DTAA) between India and US. In the instant case, the… – Continue reading

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… – Continue reading

Uber withdraws lawsuit against HCMC tax man

Ride-hailing firm Uber has withdrawn its lawsuit over HCMC’s demand for $2.3 million in back taxes and fines. A tax department official said Friday that the HCMC People’s Court has suspended the case in which the Netherlands-based Uber B.V. had sued the department over its demand that the firm pays… – Continue reading

HK-New Zealand protocol to tax treaty in force

Hong Kong (HKSAR) – The second protocol to the Comprehensive Avoidance of Double Taxation Agreement between Hong Kong and New Zealand (CDTA) entered into force yesterday (August 9), a government spokesman said. The second protocol was signed in June last year and amends the CDTA to pave the way for… – Continue reading

VN, Croatia sign agreement on double taxation avoidance

Viet Nam News HA NOI — Vietnamese Deputy Minister of Finance Do Hoang Anh Tua’n and Croatian Minister of Finance Zdravko Maric on Wednesday signed an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to income taxes. According to Tua’n, the agreement is… – Continue reading

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… – Continue reading

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… – Continue reading

NBR nod must for banks to offer double taxation avoidance benefit

National Board of Revenue has asked all banks not to allow double taxation avoidance benefits to any non-resident taxpayers without NBR certificate. International taxation wing of the revenue board has also requested Bangladesh Bank for taking necessary measures so that banks follow the directives. International tax wing of NBR on… – Continue reading

Maldives concludes first deliberations on DTAA with Singapore

Director General of Taxation Hassan Zareer represented the Maldivian state Chia-Tern Huey Min, the Deputy Commissioner of the Inland Revenue Authority of Singapore, headed a delegation of officials Double taxation occurs in international trade when the same income is taxed in two different countries Maldives and Singapore have concluded the… – Continue reading

Kenya, Portugal sign deal on removal of double taxation

Kenya and Portugal on Tuesday signed an agreement for avoidance of double taxation. The main objective of the Agreement on the Avoidance Double Taxation is to eliminate double taxation of income or gains arising in one country and paid to residents of the other country. This will create a conducive… – Continue reading

UK withholding tax on interest paid to non-residents

The UK does still have one significant disadvantage namely the 20% withholding tax imposed by UK domestic law on “yearly interest” that arises in the UK is paid to persons whose “usual place of abode” is outside the UK. The UK is normally regarded as an attractive location for the… – Continue reading

A look at the Philippines-Mexico double taxation agreement

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 58, 2018 on the Agreement for the Avoidance of Double Taxation on income tax between the Philippines and Mexico, which has entered into force last April 18, 2018. The Agreement was signed in November 17, 2015 between… – Continue reading