Category: Double Taxation

Transfer pricing — the global phenomenon

THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading

Senior Tax Officials Meet To Discuss BEPS Project

On November 3-4, 2015, more than 260 senior tax officials from 102 jurisdictions and international organizations met to discuss the tax treaty-related outcomes of the OECD’s base erosion and profit shifting project. Participants at the 20th Annual Global Forum on Tax Treaties welcomed the tax treaty-related measures agreed upon in… – Continue reading

Dr. Al-Assaf Signs Agreement of Double Taxation with Venezuelan Minister of People’s Power for Economy and Finance

Riyadh, Muharram 29, 1437, Nov 11, 2015, SPA — Dr. Ibrahim bin Abdulaziz Al-Assaf, Minister of Finance, signed here today an agreement of avoidance of double taxation and prevention of tax evasion with respect to taxes on income with Venezuelan Minister of People’s Power for Economy and Finance Rodolfo Marco… – Continue reading

The FATCA window

The implementation of the Foreign Account Tax Compliant Act is showing consistent progress with thousands of banks in over 150 countries agreeing to share financial accounts data of their US clientele with US taxation authorities. This clearly indicates the firm resolve of the US administration to make this initiative a… – Continue reading

Brazil signs agreement for information on assets in tax havens

Presidency sent to Congress ratification of treaties with Jersey, Guernsey, the Cayman Islands and Uruguay; text follows the G20 guidelines The Presidency referred for evaluation of Congress four agreements for the exchange of tax information (TIEA, which stands for the English term “Tax Information Exchange Agreement”) entered into with Uruguay,… – Continue reading

Mexico, Argentina Sign Double Tax Avoidance Agreement

Mexico and Argentina have signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital. The agreement allocates taxing rights to the two countries, to avoid taxation being levied twice on the same income from companies and individuals… – Continue reading

The Ministry of Finance proposed to soften the terms of the Amnesty

Moscow. November 10. The Finance Ministry has prepared proposals aimed to strengthen Amnesty of capital, which is now actually fails, reports the newspaper “Kommersant”. The law on the voluntary Declaration by individuals of assets and accounts, is known as the law on the legalization or Amnesty of capital, earned from… – Continue reading

BEPS: Financial transparency – the taxing question for multinationals

While proponents of the base erosion and profit shifting project claim it will facilitate appropriate taxing of global corporate profits, enforcement remains the elephant in the room, writes FX-MM’s Paul Golden. In October, the OECD presented the final package of measures for reform of international tax rules, stating that annual… – Continue reading

Transfer pricing and arm’s length principle

The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading

Implementation problems in connection with the FATCA Agreement

The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading

Deloitte Poll: US Business Executives Cite Concerns and Priorities for OECD’s Final BEPS Package

NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading

Full faith in India on tax treaty revision: Mauritius

NEW DELHI: Dismissing apprehensions of Mauritius being used to route black money as “misconception”, its Prime Minister Anerood Jugnauth has termed the issue as an aberration in the “very special” ties with India and hoped that revision of their tax treaty won’t harm its interests. Stating that Prime Minister Narendra… – Continue reading

Cash-strapped small firms may get slice of the patent box action

Small and medium-sized businesses that don’t have the resources to patent intellectual property may still be able to benefit from the Knowledge Development Box (KDP) under plans being considered by the Government. The Department of Finance is looking at allowing SMEs with patentable assets, but without the resources to get… – Continue reading

OECD BEPS Heralds Big Changes for Tax Pros and Corporate Treasurers

The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading

Protocol amending the Convention between India and Turkmenistan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital

The Union Cabinet chaired by the Prime Minister Shri Narendra Modi, has given its approval today for amending the Double Taxation Avoidance Convention (DTAC) signed between India and Turkmenistan in 1997 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income… – Continue reading

UAE signs agreement on exchange of information for tax purposes with Norway

The visit aimed to explore ways of developing and promoting the technical partnership as well as exchanging experience on financial and economic affairs between the two parties. The UAE delegation started off with a visit to the Capital of Norway Oslo, during which the Ministry of Finance (MoF), signed an… – Continue reading

Blacklisted HK: The Latvian Case

The blacklisting of Hong Kong by the European Union is over for the moment with Spain explaining to the EU it didn’t have HK on its list. In the course of investigation, Harbour Times receives a quick response from the Latvian embassy in Beijing to clarify their stance on Hong… – Continue reading

Barbados, Slovakia Sign Double Taxation Agreement

Barbados and Slovakia signed a double tax agreement on October 28, 2015, to boost investment and trade prospects. The DTA allocates taxing rights to the two territories, to ensure that cross-border income is not taxed twice. It further stipulates that cross-border income from dividends will be subject to a withholding… – Continue reading

U.S., Armenia set to talk Double Tax Treaty at bilateral meeting

PanARMENIAN.Net – The negotiation of a U.S.-Armenia Double Tax Treaty will be on the agenda of the upcoming U.S.-Armenia Economic Task Force meeting, an annual bilateral gathering taking place in Washington, DC on November 19. The Armenian National Committee of America (ANCA) welcomed the initiative, suggesting that the Administration support… – Continue reading

No revisions in main provisions of DTAA with India: Mauritius PM

Prime Minister of Mauritius, Anerood Jugnauth, on Tuesday said there will be no revisions to the main provisions of its Double Tax Avoidance Agreement (DTAA) with India as both countries are happy with the existing provisions of the tax treaty. “This treaty between our two countries has been there for… – Continue reading

Kenya: ‘Kenya Losing Billions to Tax Havens’

The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading

Buying property in Portugal shouldn’t be taxing

Buying a property overseas is an exciting venture, but also one that requires careful financial consideration. To help ease the process, Chris White, Founding Director of boutique estate agency Ideal Homes Portugal, has compiled his top tax tips for buying property in Portugal. Portugal has been called ‘Europe’s best kept… – Continue reading

Israel and Australia in tax treaty talks

An Israel delegation is scheduled to visit Australia in June 2016. The Israel Tax Authority is negotiating a treaty for prevention of double taxation with Australia, sources inform “Globes.” Tax Authority head Moshe Asher is currently in advanced talks with Australian Treasurer Joe Hockey, who himself declared that the Australian… – Continue reading

Swiss Federal Council Approves Liechtenstein, Norway DTAs

The Swiss Federal Council has adopted dispatches on a new double tax agreement (DTA) with Liechtenstein and a protocol to the agreement with Norway. The DTA with Liechtenstein was signed on July 10, 2015. It replaces the existing 1995 treaty. The agreement provides that old age and survivors’ insurance (AHV)… – Continue reading

Belgium seeks more Korean investment

Biz-friendly tax regime is one of incentives Belgium, a global hub for international government institutions, wants to attract more Korean investment with its business-friendly tax regime. At the “Belgium: Gateway to Europe” seminar at the Koreana Hotel on Oct. 27, the event host, the Embassy of Belgium, invited Bart Adams,… – Continue reading

US Administration Pushes For Swiss DTA Update Ratification

Robert Stack, US Treasury Deputy Assistant Secretary (International Tax Affairs), initiated a further push for ratification of the pending protocol to the US tax treaty with Switzerland at a hearing of the Senate Committee on Foreign Relations on October 29. Tax treaties and protocols with Switzerland, Luxembourg, Hungary, Chile, Spain,… – Continue reading

India: Procurement Services By Chinese Company Taxable As Fees For Technical Services Under India-China Tax Treaty: AAR

There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even if they… – Continue reading

Top reinsurers to open branch offices in India

IRDA norms on retrocession viewed as being restrictive Top foreign reinsurers, namely Swiss Re, Hannover Re and Scor Re would soon be applying to the insurance regulator for opening branch offices in India. The Insurance Regulatory and Development Authority (IRDA) on Friday came out with the regulations for registration and… – Continue reading

John Kasich wants new tax system for offshore profits, smaller government

Ohio Gov. John Kasich, fighting to rise in the Republican presidential race, says he would allow U.S. companies to repatriate without penalty trillions of dollars they have earned and kept offshore and then create a new system ensuring Americans aren’t double-taxed on foreign profits. “I’m for bringing the taxes down,… – Continue reading

South Africa: South African Tax Legislation: Proposed Amendments In An International Tax Context

South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading

Mauritius promises India clean and trusted jurisdiction

NEW DELHI: Often accused of being an offshore financial centre misused for round tripping, Mauritius today assured India that it will “walk the extra mile” to ensure that its reputations as clean and trusted jurisdiction is upheld at all costs. “We will put in all the necessary efforts and walk… – Continue reading

Barbados endorses OECD’s Global Standard for the Automatic Exchange of Information

Barbados has formally endorsed the AEOI global standard during a signing ceremony held in Barbados on Wednesday. The event was held in conjunction with a meeting of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes that was also hosted in Barbados. “Transparency and the exchange… – Continue reading

Comes to Switzerland on tax havens list?

Switzerland stands on a provisional Russian tax havens list: The document lists 119 countries and territories which do not ensure the exchange of tax information with Russia Russian authorities consider. If the document actually come into force as planned in the form of a regulation, threaten Russian investors in Switzerland… – Continue reading

Green light for the entry into force of the DTA between Switzerland and Argentina

Bern, 10.29.2015 – The double taxation agreement (DTA) in the area of taxes on income and on capital between Switzerland and Argentina is on 27 November 2015 to enter into force after the ratification procedures in Switzerland has been completed. It will replace the agreement of 1997 and corresponds to… – Continue reading

ITALY: INCOME TAX TREATY WITH HONG KONG ENTERS INTO FORCE

An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading

Barbados and Slovakia sign tax agreement

A DOUBLE TAXATION agreement was signed between Barbados and the Slovak Republic this afternoon. Minister of International Business Donville Inniss signed on Barbados’ behalf at a ceremony at Hilton Barbados. It is the 37th treaty signed between Barbados and another territory while Barbados became the 74th country to sign an… – Continue reading

UPDATE 1-Indonesia’s Lippo to shift REITs from Singapore to Indonesia-CEO

JAKARTA, Oct 28 (Reuters) – Indonesian conglomerate Lippo Group plans to shift two real estate investment trusts (REITs) with 35 trillion rupiah ($2.6 billion) in assets from Singapore to Indonesia next year in order to benefit from new tax breaks offered by Jakarta. Lippo’s move could be followed by at… – Continue reading

Russia Wants to Put Austria on Tax Haven List

Austria is on the preliminary list of 119 countries and territories which from the point of view of Russian authorities don’t guarantee the exchange of tax information with Russia. If the document is implemented, as planned, in form of a resolution, Russian investors in Austria will face massive tax disadvantages… – Continue reading

FRANCE: RECENT TRENDS IN TRANSFER PRICING, SURVEY

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading