Category: Double Taxation

Cambodian parliament ratifies double taxation avoidance pact with China’s Hong Kong

PHNOM PENH, Nov. 4 (Xinhua) — The Cambodian parliament on Monday ratified an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income that the country had signed with China’s Hong Kong Special Administrative Region (HKSAR). Ruling Cambodian People’s Party’s 110… – Continue reading

African authorities strive to reduce tax leakages

African tax bodies will mark the 10th anniversary of their umbrella organization, the African Tax Administration Forum (ATAF), in their efforts to reduce tax leakages. A total of 38 African countries are members of the ATAF, making the organization Africa’s largest body that collectively deals with global tax issues affecting… – Continue reading

East Africa bloc mulls regional tax treaty framework to boost integration

NAIROBI, Oct. 1 (Xinhua) — The East Africa Community (EAC) bloc plans to develop a regional tax treaty framework to boost regional integration, an official said on Tuesday. Doris Akol, commissioner general, Uganda Revenue Authority told Xinhua in Nairobi that once the treaty is in place the trading bloc will… – Continue reading

VAT on online purchase must if not paid by cos during sourcing: NBR

Value-added tax on online purchase of goods and services will be applicable if the e-commerce company concerned collects those from the original suppliers and manufacturers without paying VAT, according to the National Board of Revenue. ‘There will be no VAT on online purchase of any goods and services if the… – Continue reading

Colombia: Colombia Publishes Guidelines On Advance Pricing Agreements

Colombia's National Directorate of Taxes and Customs (DIAN) released detailed guidelines (the Guidelines) to clarify the procedure for Advanced Transfer Pricing Agreements (APAs) requests in order to ensure certainty between the parties regarding their transfer pricing arrangements. ... - Continue reading

Switzerland: Italian Tax Authorities Request Information From Switzerland On UBS Bank Customers

In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading

Canada: Canada Ratifies The Multilateral Instrument

On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance.   ... - Continue reading

Canada: Transfer Pricing: What’s New In Canada (Part II)

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

Citizenship of the Republic of Vanuatu and its advantages

The Republic of Vanuatu is a group of islands in the Pacific. The country exists by growing fruits, fishing, and tourism. In 2016, the government introduced the program of achieving local citizenship through investment to increase the flow of external finance. Foreign businessmen want to get a second passport in… – Continue reading

New Zealand-Swiss tax agreement tightens net on avoidance

WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading

Minister’s proposal of corporate tax reforms causes strong reaction from Cyprus business community

NICOSIA, Aug. 7 (Xinhua) — Cypriot Finance Minister Harris Georgiades’ proposal of a major reform of corporate taxation has triggered strong objections from entrepreneurs, who fear that it would lead to an increase of their total tax burden. Georgiades said on Wednesday that his proposal, which included taxation on offshore… – Continue reading

Nigeria: Reviewing The Implications Of The Revised Transfer Pricing Regulations On Intangibles For Businesses

Intangibles are key sources of differentiation for businesses and typically, they help drive revenue, manage cost or both. As a result, many businesses make significant investments in developing, enhancing, maintaining and protecting unique and valuable intangibles to help drive their businesses. ... - Continue reading

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading

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