Category: Double Tax Avoidance 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

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

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

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

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

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… – Continue reading

TAX TALK: LUX-FRANCE TREATY CREATES UNCERTAINTY

On the occasion of the signing of the new double taxation treaty (DTT) between Luxembourg and France on 20 March 2018, the grand duchy’s finance minister, Pierre Gramegna, commented in a government press release that the new DTT is, “…an innovative instrument that will benefit both citizens and business in… – Continue reading

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… – Continue reading

Cyprus and UK sign updated Convention on the Elimination of Double Taxation

The Republic of Cyprus and the Government of the United Kingdom of Great Britain and Northern Ireland, signed on March 22, in Nicosia, an updated Convention on the Elimination of Double Taxation with respect to Taxes on Income and on Capital Earnings and the Prevention of Tax Evasion of tax… – Continue reading

Ukraine and Qatar sign agreement on avoiding double taxation

Foreign Minister of Ukraine Pavlo Klimkin and Finance Minister of Qatar Ali Shareef Al-Emadi have signed an agreement on avoiding double taxation and preventing income tax evasion between the government of Ukraine and Qatar. According to a Thursday posting on the website of the Finance Ministry of Ukraine, avoiding double… – Continue reading

Govt. revises Agreement between India and Qatar for avoidance of double taxation

The Union Cabinet chaired by Prime Minister Narendra Modi today gave its approval for revision of the Agreement between India and Qatar for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income. The existing Double Taxation Avoidance Agreement (DTAA) with Qatar… – Continue reading

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… – Continue reading

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… – Continue reading

Netherlands Confirms Tax Treaty Negotiation Priorities

The Netherlands will seek to resume discussions towards double taxation avoidance treaties with several countries in 2018, including the United States, the Government has said. The Dutch Government will attempt to begin tax treaty talks with at least seven countries this year, including Australia, Colombia, Costa Rica, Ecuador, Morocco, Austria,… – Continue reading

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… – Continue reading

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… – Continue reading

Taiwan-Czech Republic ink double taxation avoidance pact

An agreement between Taiwan and the Czech Republic on double taxation avoidance and fiscal evasion prevention with respect to taxes on income was concluded Dec. 12 in Prague, setting the stage for increased investment and trade as well as industrial and technological cooperation between the two countries, according to the… – Continue reading

Hong Kong Finalizes FTA with ASEAN, DTAA with India

Hong Kong recently finalized a series of agreements that, taken together, shift Asia’s trade and investment landscape. On November 12, Hong Kong and ASEAN signed the ASEAN-Hong Kong, China Free Trade Agreement (AHKFTA), and the ASEAN-Hong Kong Investment Agreement (AHKIA). Prior to this, on November 10, Hong Kong and India… – Continue reading

Revised tax treaty to boost bilateral investment: Cyprus envoy

Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading

NA passes Bhutan-Bangladesh double tax avoidance agreement

The National Assembly endorsed the double taxation avoidance agreement between Bhutan and Bangladesh yesterday. Signed during the visit of Bangladesh Prime Minister Sheikh Hasina to Bhutan in April 2017, the agreement plans to do away with double taxation of incomes between the two countries. In the presence of 38 MPs,… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Irish Citizen Denied US Tax Refund On Gambling Winnings

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading

Netherlands, Uzbekistan Sign Anti-Abuse Agreement

The Netherlands has signed a protocol to its double tax avoidance treaty with Uzbekistan, designed to prevent the treaty from being inappropriately used to avoid taxes. The anti-abuse provision was signed by the Netherlands and Uzbekistan on February 7, 2017, and “prevents the benefits of the treaty only [being] used… – Continue reading

Curbs on black money abroad: Govt revising tax treaties to share data with ED, CBI

Sources said this amendment will allow speedy prosecution and imprisonment of account holders as enumerated in the Panama Papers, Liechtenstein and HSBC Geneva lists. Moving to register criminal charges and impose stricter penalties against those who have stashed black money abroad, India has started revising tax treaties with partner countries… – Continue reading

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

Finnish Royalties To Estonia No Longer Taxed

The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading

Working group to examine issues on Mauritius DTAA

NEW DELHI: The government has constituted a working group to examine the “consequential issues” arising out of the changes in India’s tax treaty with Mauritius.The India-Mauritius Double Taxation Avoidance Convention was amended last month to introduce a levy to prevent investors from using the island nation as a shelter to… – Continue reading

India-Mauritius Tax Treaty Renegotiated

On 10 May 2016, the Government of India issued a press release1 stating that India and Mauritius have signed a protocol (New Protocol) amending the double tax avoidance treaty between the two countries (the Treaty). Based on the press release and the New Protocol, following are the key changes to… – Continue reading

UAE – Jersey trade relations: from a tax haven to taxonomy

As with any offshore financial centre, secrecy has been synonymous with the Channel Islands of Jersey. But the reason for the strong relations between the self-governing British dependency and the United Arab Emirates – still not known to many – is not confidentiality alone. It has not been so long… – Continue reading

Start-up investment in India to get capital gains tax exemption

PM Narendra Modi also announces a Rs.10,000 crore fund to provide support to innovation driven enterprises New Delhi:In an effort to give a fillip to the start-up ecosystem in the country, the government on Saturday announced its intention to exempt capital gains tax on investments in start-ups and a Rs.10,000… – Continue reading