Category: Double Taxation

Pakistan money in Swiss banks dwindling for last three years

LONDON: Money kept by Pakistani nationals and enterprises in Swiss banks fell by 33 per cent to a record low of CHF380 million (Rs63 billion) in 2018, falling below the level of Indian funds for the first time in four years, Swiss National Bank’s (SNB) annual statistics report showed on… – Continue reading

Tax on reserve to hit cos’ business expansion: ICAB

The imposition of 15 per cent tax on reserve and retained earnings of listed companies will reduce capital and expansion scope of the companies, said the Institute of Chartered Accountants of Bangladesh on Saturday. The ICAB made the statement in its post-budget review. Finance minister AHM Mustafa Kamal placed the… – Continue reading

Luxembourg: Tax Dispute Resolution Mechanism

The Bill of Law 7431 (“Bill”) introduced by the Luxembourg government on 11 April 2019 implements the European Union (“EU”) Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU (the “Directive”). The Directive meets the BEPS Action Plan 14 minimum standards and is a subsidiary… – Continue reading

India: Split Residency – ITAT Upholds The Taxpayer’s Claim For Treaty Exemption, Applies Centre Of Vital Interest Test

Dual Residency gets attracted when an expat in the year of move qualifies as a resident of the host country (i.e., the country in which he is deputed) as well as home country (i.e., the country of his residence). On account of dual residency, an expat can be doubly taxed… – Continue reading

Delving into Hong Kong’s New Transfer Pricing Landscape

On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill).  This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading

NBR for 30pc job quota for Bangladeshis

The National Board of Revenue recommended that the proposed guidelines on local entrepreneurs’ overseas investment should include provisions that the interested businesses have no overdue taxes in Bangladesh and have to employ minimum 30 per cent Bangladeshis in overseas projects. The NBR made the suggestions in its observations sent last… – 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

Cyprus and Kazakhstan sign Double Taxation Convention

The Republic of Cyprus and Kazakhstan signed on Wednesday a Convention for the Avoidance of Double Taxation and for the combating of Tax Evasion with respect to taxes on income. According to a press release issued by the Public Information Office, the Convention was signed in Nursultan, Kazakhstan, by the… – Continue reading

FIRS Vows to Eliminate Multiple Taxation

Obinna Chima The Executive Chairman, Federal Inland Revenue Service (FIRS), Mr. Babatunde Fowler, has restated the agency’s commitment to eliminating multiple taxation in the country. Fowler said this at a tax breakfast seminar with the theme: “Tax Controversy and Dispute Resolution,’ organised by KPMG Nigeria in Lagos, recently. According to… – Continue reading

Kuwait, Iraq ink several cooperation agreements

KUWAIT: The Kuwaiti-Iraqi joint committee held its seventh session in Kuwait on Sunday under the chairmanship of Deputy Prime Minister and Minister of Foreign Affairs Sheikh Sabah Al-Khaled Al-Hamad Al-Sabah and Iraqi Foreign Minister Dr Mohammad Ali Al-Hakim. The session resulted in the signing of a number of agreements, memorandums… – Continue reading

Joint tax mechanism to enhance trade & investment among BRI countries

A new mechanism aimed at creating a more favorable tax environment for enterprises and countries involved in China’s Belt and Road Initiative (BRI) has been established. Tax officials and experts from dozens of countries and international organizations have gathered in China from April 18 to 20 for the first Belt… – Continue reading

HMRC targets accountants over tax evading clients

HMRC sent 1,414 requests to professional services firms demanding confidential information on clients suspected of tax evasion in the 12 months to 31 March 2018, according to law firm RPC. The production orders are issued by HMRC’s Criminal Investigation Directorate to force third parties, such as accountants, lawyers and other… – Continue reading

Foreign income declaration mandatory

KARACHI: The income tax law has made it mandatory for taxpayers to declare foreign income and assets in order to avoid penalty, Vishno Raja Qavi, former chief tax policy, Federal Board of Revenue (FBR), said on Thursday. He was highlighting the key points of Automatic Exchange of Information (AEOI) at… – Continue reading

Steven Gerrard sues HSBC for £100m over tax schemes

Rangers manager Steven Gerrard is taking legal action against his wealth manager following a crack down on tax avoidance schemes. The former Liverpool captain is among hundreds of investors who have launched a £100m lawsuit against HSBC’s private banking division, claiming it defrauded them, The Times has reported. Composer Lord… – Continue reading

Ukraine, Switzerland sign protocol on avoidance of double taxation

Ukraine and Switzerland have signed a protocol on the introduction of amendments to the convention on the avoidance of double taxation with respect to taxes on income and capital, and its protocol, concluded in Kyiv on October 30, 2000. Ukrainian Finance Minister Oksana Markarova and newly appointed Swiss President Ueli… – Continue reading

Angola’s parliament approves elimination of double taxation with Portugal, China and UAE

The Angolan parliament unanimously approved proposals for the resolution of agreements for the elimination of double taxation and prevention of tax evasion on income tax with Portugal, China and the United Arab Emirates (UAE), according to official information. The Secretary of State for Cooperation, Domingos Vieira Lopes, said that the… – Continue reading

Portugal: Portuguese Golden Visa – Investment Route And The Non-Habitual Residents Regime

Background Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe. Portugal is increasingly recognised as an international hub with 71 Double Taxation… – Continue reading

End of double taxation between Angola and Portugal approved in Lisbon

The Portuguese Parliament voted in favour of a proposed government resolution approving the agreement to eliminate double taxation with Angola, the Portuguese press reported on Friday. The parliament unanimously approved an agreement between Portugal and Angola on mutual administrative assistance and co-operation in fiscal matters signed in Luanda on 18… – Continue reading

Avoidance of double taxation treaty between India, HKSAR comes into effect

A double taxation avoidance agreement between India and Hong Kong has come into effect from Friday, which officials say would stimulate more the two-way flow of investments and help curb fiscal evasion with respect to taxes on income. The agreement between India and the Hong Kong Special Administrative Region (HKSAR)… – Continue reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – 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

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

Brazil and United Arab Emirates sign agreement to eliminate double taxation

Convention signed on Monday will facilitate investments, can reduce tax evasion Brazil and the United Arab Emirates signed an agreement to eliminate double taxation on income and prevent tax evasion and tax avoidance. The document was signed on Monday (12 November) by Brazilian Foreign Minister Aloysio Nunes Ferreira and UAE… – 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

Applying for China’s DTA Benefits in Profit Repatriation

China’s double tax avoidance agreements (DTAs) can be used to avail lower tax rates while making outbound payments. However, DTA benefits are not automatically applicable to everyone. Foreign invested enterprises and their overseas headquarters must satisfy certain qualifications and go through relevant procedures to obtain the benefits. Beneficial owner assessment… – Continue reading

Defying US, India inks $5 bn deal with Russia

NEW DELHI: India and Russia are exploring the option of trading in their local currencies and looking at signing agreements on investment protection and avoidance of double taxation, Russia’s minister for economic development Maxim Oreshkin said on Friday. The commerce ministry is considering the feasibility of a renminbi-rupee trade with… – 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

IN UKRAINE A NUMBER OF TAXES IS TOO HIGH – EXPERT

In Ukraine in some areas taxes are too high, and entrepreneurs simply can’t pay, so toughen system of tracking defaulters only after tax cuts. Comments about this correspondent of ГолосUA said political analyst Nikolai Spiridonov. “In Ukraine, a number of taxes too high. Businesses simply can’t pay. And is double… – 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