Category: Double Taxation

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding...

New Private Tax Ruling Clarifies the Conditions for New Immigrants to Obtain an Israeli Residency Certificate

Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not...

Inland Revenue Ordinance to be amended to facilitate international tax co-operation

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 5) Bill 2017 (Amendment Bill) was gazetted today (October 6). The Amendment Bill seeks to pave the way for Hong Kong’s participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and to align the Inland Revenue Ordinance (IRO)...

EU eyes corporate rules shake-up with law on seat transfer

The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for...

Hong Kong to examine tax concessions to attract global funds, Financial Secretary says

Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the...

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...

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country...

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a...

UK: The UK Company: A Tax-Efficient Business Vehicle For International Investors

This article is the third of a series of articles that examines 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 in other offshore financial centres....

Israel, Armenia Sign MoU on Abolishing Double Taxation

Israel wants to develop friendly relations with Armenia, according to that country’s Regional Cooperation Minister, Tsakhi Hanegbi, who told Foreign Minister Edward Nalbandian on Wednesday as he kicked off an official visit to Armenia. He said that the purpose of his visit was to advance those ties. The two signed...

Push to draw up Cambodia-Thai tax treaty

Representatives from the tax authorities of Cambodia and Thailand have agreed in principle to speed up a proposed double taxation agreement that would protect their nationals from dual taxation and encourage bilateral investment. The agreement was made last week during a two-day consultation workshop in Bangkok for tax officials from...

Enhancing diplomatic and economic ties: Ghana-Czech Republic Double Tax Agreement to come into force in 2018

Ghana signed another Double Tax Agreement (DTA) with the Czech Republic on 11 April, 2017. Ghana already has DTAs in force with Denmark, the United Kingdom, Belgium, Italy, South Africa, Switzerland, Netherlands, France and Germany. DTAs with Mauritius, Singapore and the Czech Republic are in the process of being ratified...