Category: Double Tax Treaty

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their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not...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their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not...

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...

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...

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...

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...

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...

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...

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...

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...

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax...

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a...

ANCA and Senator Menendez Discuss Benefits of a U.S.-Armenia Double Tax Treaty

Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral...

Opportunity for Refund of Late Interest charged on Failed Withholding Tax Notifications

Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income....

Austria: Ministry Of Finance Issues Guidance On The Alienation Of A Partnership Stake In A Trilateral Setting

On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident...

New Double Tax Treaty signed between Montenegro and Portugal

Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income...

Russia Removes Hong Kong From List of Offshore Tax Zones

The Russian government will no longer consider Hong Kong a Chinese-affiliated tax haven that doesn’t share tax information. Russia will strike Hong Kong from its list of offshore jurisdictions following ratification of a double tax treaty signed by the two parties last January and ratified by Russia in July, according...

Special tax regime for Non-Habitual Portuguese Resident individuals

Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will...