Category: Double Tax Treaty

Bangladesh / Czech Republic / Double Tax Treaty / Double Taxation / Investments / Tax Authority

Dhaka, Prague sign deal to avoid double taxation

Posted On: December 12, 2019

Bangladesh and the Czech Republic have signed a double taxation avoidance agreement (DTAA) in a bid to strengthen bilateral trade and investment ties between the two countries. National Board of Revenue (NBR) chairman Md Mosharraf Hossain Bhuiyan and Czech deputy prime minister and finance minister Alena Schillerova inked the agreement… – Continue reading

Corporate Tax / Double Tax Treaty / Income Tax / Malaysia / Russia / Tax Evasion / Ukraine

Parliament ratifies double tax agreement with Malaysia

Posted On: October 30, 2019

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

Arbitration / Banking Secrecy / Capital Gains Tax / Dividends / Double Tax Treaty / Intellectual Property / Loans / Mutual Agreement Procedure / Permanent establishment / Royalties / Tax Credit / Tax Exempt / Ukraine

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

Published by: Mondaq - September 30, 2019

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 / Business / Double Tax Treaty / Framework / Malta / Tax Evasion

Armenia, Malta sign double tax treaty

Posted On: September 25, 2019

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

Citizenship / Double Tax Treaty / Expats / FATCA / Internal Revenue Service (IRS) / Residence / Tax Laws / Tax Reform / USA

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

Posted On: September 18, 2019

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

Double Tax Treaty / EU / European Commission / Luxembourg / Tax Authority / Tax Laws / USA

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

Published by: Mondaq - August 26, 2019

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

Automatic Exchange of Information / Business / Corruption / Double Tax Avoidance Treaty / Jurisdiction / Multilateral Competent Authority Agreement / OECD / Pakistan / UAE

Govt launches crackdown on benami assets

Posted On: August 24, 2019

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

Anti-Tax Avoidance Package / Banking / Double Tax Treaty / Individuals / Jurisdiction / Luxembourg / Tax Avoidance / Tax Credit / Tax Relief

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

Published by: mondaq - August 16, 2019

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

Capital Gains Tax / Double Tax Treaty / Exemptions / HM Revenue & Customs / Legislation / Luxembourg / Real Estate / Residence / Tax Laws / Tax Transparency / United Kingdom

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

Published by: Mondaq - July 24, 2019

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

Base Erosion & Profit Shifting / Double Tax Avoidance Treaty / EU / Gibraltar / Investments / Jurisdiction / OECD / Tax Avoidance / Tax Transparency / Tax treaties / United Kingdom

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

Posted On: July 15, 2019

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

Business / Cambodia / Double Tax Avoidance Treaty / Gaming / Government Bodies / Investments / Kenya / Laos / Offshore / Philippines / Revenue / Tax Authority / Tax treaties / Turkey / Vietnam

Pagcor: Government not inclined to impose higher taxes on POGOs

Posted On: July 15, 2019

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

Business / Central Board of Direct Taxes (CBDT) / Double Tax Avoidance Treaty / India / Mauritius / Residency / Tax Authority / Tax Avoidance / Tax Fraud / Tax treaties / Vodafone / Withholding Tax

India: Bombay High Court Quashes 197 Order Rejecting Mauritius Tax Treaty Benefits

Posted On: May 31, 2019

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

Capital gains / Cyprus / Dividends / Double Tax Treaty / Interest / Kazakhstan / Legislation / Residence / Royalties / Withholding Tax

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

Posted On: May 29, 2019

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

Bulgaria / Double Tax Treaty / Double Taxation / EU / Hong Kong / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / Offshore / Pakistan / Switzerland / Tax Evasion / Tax Laws

Pakistan, Bulgaria sign double taxation treaty

Posted On: May 22, 2019

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

Brunei / China / Double Tax Treaty / Investments / Tax Collection / Tax Evasion / Tax Laws / Vietnam

Double tax agreements come into force

Posted On: January 3, 2019

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

Austria / Budget / Double Tax Treaty / Gaar / HM Revenue & Customs / Income Tax / Japan / Legislation / New Zealand / OECD / Property / Residence / South Africa / United Kingdom

Worldwide: UK Tax Round Up – November 2018

Posted On: November 30, 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

Canada / Double Tax Treaty / Double Taxation / Income Tax / Pakistan / Residence / UAE / United Kingdom

FBR urged to clarify taxability of foreign rental income

Posted On: November 28, 2018

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

Banking / Double Tax Treaty / Income Tax Act / Non-resident Enterprises / Residence / Tax Authority / Tax Evasion

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

Posted On: November 28, 2018

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

Base Erosion & Profit Shifting / China / Double Tax Treaty / Income Tax Act / India / Legislation / Tax Evasion

India-China amends double taxation avoidance treaty

Posted On: November 26, 2018

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

Automatic Exchange of Information / Base Erosion & Profit Shifting / Beneficial Ownership / Brazil / Dividends / Double Tax Treaty / Financial markets / Interest / Investments / Loans / Royalties / Switzerland / Tax Laws / Withholding Tax

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

Posted On: November 23, 2018

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

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