The US Internal Revenue Service (IRS) has said it will consider certain circumstances in which it could provide relief from double taxation resulting from application of the repatriation tax, as amended by the Tax Cuts and Jobs Act (TCJA) 2018. ... - Continue reading
A possible double tax treaty is to be expected between the Philippines and Cambodia. ... - Continue reading
The government of Malaysia is putting into effect several measures in an attempt to prevent double taxation arising from digital tax. ... - Continue reading
Bangladesh and the Czech Republic have signed a double taxation avoidance agreement (DTAA) in a bid to strengthen bilateral trade and investment ties between the two countries. National Board of Revenue (NBR) chairman Md Mosharraf Hossain Bhuiyan and Czech deputy prime minister and finance minister Alena Schillerova inked the agreement… – Continue reading
Pakistan gives warning over transparency to UAE ... - Continue reading
The decision was taken at a meeting of the Union Cabinet chaired by Prime Minister Narendra Modi. ... - Continue reading
For Macau residents, double taxation will be avoided by way of exemption of the income taxed in Hong Kong from the Macau tax, or by crediting the Hong Kong tax paid against the Macau tax payable in respect of the same income. ... - Continue reading
A proposal by the Organisation for Economic Cooperation and Development that effectively seeks to establish a global minimum rate of corporate taxation ignores that Cayman’s tax neutral status is not harmful and is a viable alternative for eliminating double taxation and tax conflicts, says Jude Scott, the chief executive of… – Continue reading
Taxpayers are invited to submit comments on their experiences by December 16 through filling out a taxpayer input questionnaire. ... - Continue reading
Double taxation agreement signed between Ukraine and Cyprus ... - Continue reading
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. ... - Continue reading
Taxation has become an increasingly global issue as people, money and property move freely across borders. ... - Continue reading
Substance is vital when it comes to the tax residency of companies and their management and control aspect. ... - Continue reading
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 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
HMRC has recently been consulting on how the UK will implement new EU disclosure rules contained in the latest Directive on Administrative Cooperation (DAC6). ... - Continue reading
Highlights of the “unified approach to pillar one” proposal ... - Continue reading
Is it true that if I become Italian I have to pay taxes in Italy? “I am a U.S. citizen and I plan to move my residency to Italy. I will continue working remotely for my U.S.-based company and will continue paying my taxes in the U.S. What should I… – Continue reading
If you wish to retain the NRI status to avoid clubbing of US salary with Indian income for tax purposes, it would be advisable for you to restrict your stay in India to less than 60 days during FY20 ... - Continue reading
LAHORE: Lahore traders having failed to convince the Federal Board of Revenue on taxation measures have sought the assistance of the Lahore Chamber of Commerce and Industry (LCCI) to plead their case, a statement said on Saturday. LCCI President Irfan Iqbal Sheikh, Senior Vice President Ali Hussam Asghar and Vice… – Continue reading
Last week saw Cyprus add The Netherlands to the long list of countries with which it has signed double taxation agreements. ... - Continue reading
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
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. ... - Continue reading
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
The governments of New Zealand and Guernsey on September 18 signed protocol to their tax information exchange agreement, the New Zealand government has announced. ... - Continue reading
You may evaluate claiming foreign tax credits under the India-US Double Tax Avoidance Agreement, for the taxes, if any, paid in the US on the salary received during the assignment, subject to satisfaction of conditions ... - Continue reading
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
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
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
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
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
One of the key objectives of the Income Tax (Transfer Pricing) Regulations, 2018 (NTPR) as captured in regulation 2(e) is to provide taxable persons with certainty of transfer pricing treatment in Nigeria. ... - Continue reading
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
The European Union has added further impetus to its objective of providing greater transparency with regard to harmful tax practices through an amendment to EU Directive 2011/16/EU. ... - Continue reading
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
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
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
The proposal intends to tax gift of money exceeding ₹50,000 made by residents to non-residents that were earlier claimed to be outside the ambit of India taxation ... - Continue reading
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
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
G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. ... - Continue reading
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
We are working at it,” said Salman F Rahman, prime minister’s adviser on private sector development, while replying to a question on Monday at the dissemination of ‘World Investment Report 2019’ in Dhaka. Finance Minister AHM Mustafa Kamal has proposed to impose an additional 15 percent tax on the retained… – Continue reading
Guide to Cash Pools And Transfer Pricing ... - Continue reading
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
Double tax agreement set to be modernised. ... - Continue reading
Transfer pricing positions to be reviewed by IRS ... - Continue reading
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
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
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
