Last summer, a client received a letter from their bank, a major German bank in which it was asked to indicate “whether you are a US tax or not” and also in the form of an affidavit (“Under penalties of perjury”) in to make English more detailed information about himself… – Continue reading
The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading
Abuja – The speaker of the House of Representatives, Rt. Hon Yakubu Dogara, yesterday reiterated the resolve of the legislature to domesticate all pending treaties, memoranda of understanding and agreements that will bring benefit to Nigerians. Dogara said this while speaking to a Korean delegation that paid him a courtesy… – Continue reading
PRESS RELEASE Mauritius and Morocco signed on November 25 in Port Louis a Double Taxation Avoidance Agreement (DTAA) that will provide for greater tax certainty for businessmen of the two countries. The signatories were the Minister of Finance and Economic Development, Mr Vishnu Lutchmeenaraidoo, and the Ambassador of the Kingdom… – Continue reading
The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading
Introduction Transfer pricing is a term used to define the price charged between associated enterprises for the transfer of goods, services and intangible property. Increasing cross-border activities have made transfer pricing a real issue as enterprises seek to use transfer pricing as a tool for tax avoidance. Consequently, HK has… – Continue reading
In response to the announcement that pharmaceutical firms Pfizer and Allergan would merge, Hillary Clinton released a statement that completely missed the real issue behind these inversions – they are a symptom of the greedy, complex, and inefficient U.S. tax code. “Inversion is a symptom, not a disease,” said Grover… – Continue reading
The Central Board of Direct Taxes (CBDT), Government of India, via press release dated September 24, 2015, assured the inapplicability of Minimum Alternate Tax (MAT) provisions to Foreign Companies with effect from 01.04.2001. The Government recently issued a circular, accepting the recommendations of the Committee (A P Shah Committee) appointed… – Continue reading
The Governments of the United Arab Emirates and Republic of South Africa have signed an agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital gains, and its annexed protocol. Inked by Hamad Hareb Al Habsi, UAE Ambassador to South… – Continue reading
The number of Swiss institutions have seen “asset outflows” and the tax status of many of their clients have been found to be “inappropriate”, as per the Swiss Financial Market Supervisory Authority (FINMA), which also has the mandate to combat money laundering activities. Switzerland authorities revealed on Tuesday that India… – Continue reading
COUNTIES should harmonise taxes to promote intra-county trade and attract investments, the Kenya National Chamber of Commerce and Industry has said. KNCCI chairman Kiprono Kittony yesterday said high and uncordinated taxes and levies are unfavorable for businesses, a move that has kept trade low between counties. He said the business… – Continue reading
In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries. This policy is expected to continue in the future. To date, treaties are in force with… – Continue reading
Bern, 11.24.2015 – Four additional double taxation agreements (DTAs) have entered into force between Switzerland and Cyprus, Iceland, Estonia and Uzbekistan. They contain provisions on mutual assistance in accordance with the internationally applicable standard. At the same time they promote the development of bilateral economic relations. With Cyprus, Switzerland has… – Continue reading
Bern, 24.11.2015 – On 23 November 2015, Switzerland and Brazil signed in Brasilia an agreement on the exchange of information on tax matters (“Tax Information Exchange Agreement” TIEA). The Agreement with Brazil is the tenth TIEA signed by Switzerland. The agreement deepens the bilateral relations between Switzerland and Brazil. Switzerland… – Continue reading
Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading
SARS may now impose a dividends tax on dividends paid by a South African company to a Cypriot shareholder as provided for in the Protocol to the current agreement for the avoidance of double taxation between South Africa and Cyprus. In terms of the current agreement for the avoidance of… – Continue reading
SINGAPORE-listed Sinarmas Land is looking to unlock the value of its investment properties in Indonesia by spinning them into a real estate investment trust (Reit) but has not decided on whether to list in Singapore or Jakarta, with tax benefits on offer likely to be a key determinant. “The unlocking… – Continue reading
YEREVAN, NOVEMBER 23, ARMENPRESS. A businessman should not pay the same tax for two times for a unilateral deal. The agreement of avoidance of double taxation with respect of taxes on income and on capital signed between Armenia and the USA is one of the factors that will contribute to… – Continue reading
Nawaz Sharif has turned his full attention for close relations with Central Asian states since the five of them broke away from Russia 23 years ago. Fast track negotiations between Central Asian and Pakistani leaderships are slated to turn their countries into a big, new economic zone. Their desire and… – Continue reading
On the face of it, Malta literally has the highest corporate tax rate in the EU. At 35%, it hardly seems to be a competitor to European tax havens like Ireland and Cyprus, both applying a rate of 12.5%, or territories like Gibraltar. At a rate of 10%, the latter… – Continue reading
Nov 22, 2015- Lack of clarity over double taxation on petroleum products from China will delay the signing commercial agreement with Petro-China. For now, the government is sending a technical team of Nepal Oil Corporation (NOC) to China on Monday to clarify the issue of taxation before a high level… – Continue reading
The blacklisting saga did not start with Spain, but it did end with a timely correction related to it. Harbour Times explains how Hong Kong was taken off the Spanish tax haven list. Friends of Harbour Times would be familiar with the remedy of Hong Kong being named a non-cooperative… – Continue reading
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
The governments of Malta and the Caribbean island of Caraçao have signed a treaty, which both sides say will prevent tax evasion and the double taxation of companies operating in both jurisdictions. In line with internationally agreed standards, Malta’s finance minister Edward Scicluna and his counterpart from Caraçuo Jose Jardim… – Continue reading
Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading
Under the Double Taxation Treaties (“DTT“) General Communiqué (Serial No. 3) (published in the Official Gazette dated July 15, 2015 and No.29417); it is stated that in cases where the incomes earned by individuals and legal entities resident in Germany through their professional services in Turkey are taxed through withholding… – Continue reading
If statistics are anything to go by, today India is the world’s fastest growing economy at 7.3% in 2015, outstripping the global average of 3.1%. With a new government in the centre, we do seem to be riding high on the growth trajectory. The Modi government has certainly done its… – Continue reading
Sign protocol to avoid double taxation Observer Report Wednesday, November 18, 2015 – Tashkent—Prime Minister Nawaz Sharif has said his government is keen to enhance connectivity in the region and wants to increase cooperation with Uzbekistan. In a meeting with Uzbek President Islam Karimov in Tashkent on Tuesday, Nawaz said… – Continue reading
Hong Kong (HKSAR) – The Financial Secretary, Mr John C Tsang, on behalf of the Government of the Hong Kong Special Administrative Region, today (November 18), signed in Bucharest an agreement on the avoidance of double taxation with Romania. Romania’s State Secretary for Public Finance, Mr Attila Gy?rgy, signed on… – Continue reading
The Union Cabinet chaired by the Prime Minister Shri Narendra Modi has given its approval for the protocol amending the Agreement between India and Kuwait for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The Protocol provides for internationally accepted standards… – Continue reading
TAIPEI — Japan and Taiwan will sign a bilateral tax treaty aimed at improving the flow of people and investment between the two economies, sources familiar with the matter said on Wednesday. The treaty will reduce or eliminate taxes on dividends repatriated from companies’ overseas branches and help avoid issues… – Continue reading
Policies on perks, more bilateral pacts can help generate funds for growth: Accounting firm Singapore’s tax system can be improved to ensure the country can generate the funds needed for long-term growth and development, according to a white paper from accounting giant PwC yesterday. It called for policies that ensure… – Continue reading
Under Indian foreign exchange regulations, Indian companies having foreign investment participation are generally categorised either as Indian owned and controlled company (IOCC), or foreign owned or controlled company (FOCC). An Indian company in such cases is considered as IOCC where they are owned and controlled by resident Indian citizens and/or… – Continue reading
JAKARTA (REUTERS)- Indonesia is considering offering tax incentives for employees as part of the country’s current efforts to spur economic growth through changes to its tax regime, Coordinating Minister for Economics Darmin Nasution said on Tuesday (Nov 17). The government of South-east Asia’s largest economy has introduced several other incentives… – Continue reading
Hong Kong (HKSAR) – The Financial Secretary, Mr John C Tsang, arrived at Bucharest, Romania today (November 17, Bucharest time), for his two-day visit to strengthen economic and trade ties between Hong Kong and Romania. Mr Tsang first held a meeting with the Representatives of the Romanian Banking Association. Mr… – Continue reading
Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading
Amman, Nov. 17 (Petra)– Jordan and the United Arab Emirates held a fifth round of trade talks Tuesday here with the aim of inking an Avoidance of Double Taxation Agreement (DTAA). The agreement helps the taxpayer to get relief from double taxation on the same income. Director general of the… – Continue reading
2nd Symposium of CR for transfer pricing The 2nd Symposium Transfer Pricing organized by EY Greece, exactly one year after the successful organization of the 1st Symposium was intended as the developments in transfer pricing in Greece and international tax developments, focusing on the recently finalized OECD Actions tackling Erosion… – Continue reading
The value of import exemptions for the first nine months of this year exceeded what the government has budgeted for the period by more than a billion Ghana cedis. The revised budget of government estimated the value of import exemptions for the first three quarters of the year at a… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading
A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading
Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading
On October 6, 2015 Poland and Sri Lanka concluded a new Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the DTA). When entering into force this new DTA will replace the existing Double Taxation Agreement (stemming from 1980)… – Continue reading
The voluntary disclosure is passing under the banner of the last kilometer. By November 30, the games will be made. One can already say that the operation is a success announced. Order of Chartered Accountants of Milan has estimated that the transaction will derive from the tax authorities at least… – Continue reading
Once again, a possible corporate inversion is making headlines and once again, the Obama administration has proven it does not understand the real reason inversions occur. In response to news that pharmaceutical firms Pfizer and Allergan are in merger discussions, the Obama Treasury department has suggested it would do its… – Continue reading
On November 13, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper setting out planned negotiations on Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs). According to the policy paper HMRC will begin negotiations on double taxation agreements with: • Nepal • Romania • Trinidad… – Continue reading
Jakarta (ANTARA News) – The government step to offer cuts on income tax for firms willing to revaluate their assets, as promised in its economic policy package, has received positive responses from many companies. Finance Minister Bambang Brodjonegoro is convinced that numerous companies have been interested in conducting asset revaluations… – Continue reading
Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment eight pending US tax treaties and protocols. Proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual… – Continue reading
Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading
