Category: Double Taxation

Austria: Successful Appeal Regarding Taxation Of Foreign Interest Income

On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries. An Austrian taxpayer received interest from Greek, Brazilian and Argentinian government bonds between 2003 and 2007. According to the… – Continue reading

Uganda: Multinationals Should Pay Full Taxes, African MPs Say

Entebbe — Members of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) want governments across the continent to put more pressure on multinational companies to pay full taxes. According to the parliamentarians, tax evasion and illicit financial flow (IFFs) from Africa can be brought to an end if… – Continue reading

Cabo Verde approves agreement to avoid double taxation with Guinea-Bissau

The government of Cabo Verde (Cape Verde) approved an agreement to avoid double taxation with Guinea-Bissau, aimed at preventing tax evasion and fostering economic relations between the two countries, according to an official statement issued following a Cabinet meeting. The statement issued Friday said that the approved agreement, signed in… – Continue reading

Govt will not extend black money compliance window beyond Sept 30

New Delhi, Sept 22 (KNN) Government will not extend the window for declaration of black money assets held abroad beyond September 30, said Joint Secretary, Central Board of Direct Taxes (CBDT), Ministry of Finance, V Anandarajan. While inaugurating the conference on ‘Black Money Act: Ignorance is not Bliss! – Key… – Continue reading

Singapore Urges Need For Tax Competition After BEPS

Global convergence towards higher tax rates globally would be a poor outcome for the base erosion and profit shifting (BEPS) project and a severe impediment to uplifting global growth prospects, Josephine Teo, Singapore’s Senior Minister of State for Finance and Transport, has said. Speaking at the SMU-TA Centre for Excellence… – Continue reading

CHINA: TRANSFER PRICING DISCUSSION DRAFT; BEPS INFLUENCE

China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading

Uzbekistan, Iran discuss co-op in trade, economic sphere

Issues of the Uzbek-Iranian bilateral relations’ development were discussed during the meeting of Uzbek Foreign Minister Abdulaziz Kamilov with Iranian Ambassador Ali Mardoniy Fard, who is completing his diplomatic mission in the country, said the message released Sept.16 by the foreign ministry of Uzbekistan. During the meeting, the sides exchanged… – Continue reading

“United States: New Jersey Tax Court Finds Royalty Company Must File And Pay Even Though Related Entity Paid Tax On Same Income “

In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading

The Netherlands – Budget 2016

On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading

Mombasa county has launched another attempt to collect levies on cargo at the port after earlier attempts were rejected by the Kenya Ports Authority (KPA). Through the Finance Bill 2015/2016, the county wants to directly tax shipping lines and cargo owners unlike in the previous bid where it sought to… – Continue reading

Tax: Why it is important to report your foreign assets and income

Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident (NOR) and Non-Resident (NR). Reporting and paying taxes on overseas incomes and assets come with their own set of challenges. Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident… – Continue reading

High U.S. Tax Rates Force American Companies to Flee Overseas

The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading

Tax-Qualified Retirement Plans: Special Rules Apply to Withholding on Distributions to Non-Resident Aliens

Administrators of tax-qualified retirement plans (or their delegated payor) are responsible for both withholding on distributions and for reporting the tax withheld. If taxes are under-withheld, the administrator/delegated payor may be subject to penalties. Although the rules governing withholding on distributions to US citizens and resident aliens are clear and… – Continue reading

IFA Annual Congress: practical protection of tax payers’ rights and BEPS in focus

There are often a few major issues on everyone’s lips in the international community of tax lawyers. This was the case also at The International Fiscal Association’s (IFA) 69th Congress in Basel, Switzerland. One of the main subjects in the congress was how tax payers’ rights can be most efficiently… – Continue reading

Netherlands: Luxembourg Bill Implements Anti-Abuse And Anti-Hybrid Rules For EU Intra-Group Dividends

Luxembourg recently published a bill to implement the new anti-hybrid rule and the general anti-abuse rule (GAAR) of the EU Parent Subsidiary Directive (PSD). The bill closely follows the wording of the PSD. A similar Dutch bill is expected on 15 September 2015. While the Dutch bill may differ from… – Continue reading

KMT to push cross-strait taxation pact in new legislative session

Taipei, Sept. 14 (CNA) The Kuomintang (KMT) government will be prioritizing passage of a cross-strait agreement on double taxation avoidance as well as bills on the budget, government restructuring and an all-volunteer military in the fall legislative session that opens Tuesday, Premier Mao Chi-kuo (毛治國) said Monday. Mao said the… – Continue reading

Vietnam-US double taxation avoidance will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading

Ukraine – Cyprus Double Taxation agreement – details

Negotiations took place, on 2 July 2015, at the Ministry of Finance of the Republic of Cyprus, concluding a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income, when it expires. The agreed protocol, when… – Continue reading

Editorial: Financed from India

Given how China is trying to internationalise its currency, including getting more countries to settle trade in local currencies, it is not surprising that Indian policy-makers are looking at how to increase the rupee’s international acceptability. While that will have to wait till the Indian economy acquires China’s heft, a… – Continue reading

Vice Custodian of the Two Holy Mosques chairs the Cabinet session 3 Jeddah

The Cabinet, then discussed a number of domestic issues and, in this regard, expressed thanks to and appreciation of the competent security agencies and Saudi Customs for their following-up, monitoring and preventing drug smuggling attempts into the Kingdom and the arrest of those involved in the smuggling and their recipients,… – Continue reading

Transfer pricing remains thorny issue for international trade

Multinational companies are facing far more expansive and complex audits by tax authorities fighting over the same pot of profits as budget deficits continue to increase, reports BD Live. An inevitable outcome of efforts globally to prevent tax bases from erosion is double taxation and increased disputes over adjusted assessments… – Continue reading

Taxpayers facing double taxation due to different provincial laws: KTBA

KARACHI: The provincial finance ministries have been urged to resolve their differences on rights of taxability among themselves, as taxpayers are facing double taxation on services on the basis of origin and destination. In communications sent on Monday to ministers of finance of Sindh, Punjab, Khyber-Pakhtunkhwa and Balochistan, the Karachi… – Continue reading

Big UK companies halve provisions for disputed tax bills

The amount big companies set aside to cover disputed tax bills has more than halved over the past three years to £1.7bn this year, reports the Financial Times. Even though businesses fear more disputes as tax authorities become increasingly tough, they are showing reluctance to be drawn into conflicts that… – Continue reading

Iran, Iraq sign three major economic agreements

Tehran, Sept 6, IRNA – Economy Minister Ali Tayyebnia and visiting Iraqi Finance Minister Hoshyar Zebari, in a meeting on Sunday, signed three strategic economic agreements. The three agreements were about customs cooperation, avoiding double taxation and encouraging joint investments. Tayyebnia said that Iran-Iraq trade, including other cooperation such as… – Continue reading

Latest Central Bank move on banking oversight will help reduce risk

Lack of information about ‘opaque’ special purpose vehicles make it difficult to assess financial stability implications The legendary Warren Buffett once described some shadow banking activities as “financial weapons of mass destruction”. By that he meant they pose a huge threat to the global financial system, as these investment structures… – Continue reading

Canadians Owning Property in the U.S. Could Cash in on the Weak Loonie

For the past few years, Canadians have been taking advantage of our dollar being worth about the same as the U.S. dollar. From buying up real estate to cross-border shopping, being on par with the U.S. dollar has had its advantages. However, in the last few months, economic factors have… – Continue reading

CORPORATE CLOSE-UP: LICENSING SUBSIDIARY THAT FELL PREY TO ADDBACK REQUIREMENT MUST ALSO FILE RETURN, NEW JERSEY RULES

Shifting of income between parent and subsidiary companies for the purpose of avoiding taxation has been a consistent concern for state departments of revenue. States have enacted a variety of rules to ensure that the entities involved file and pay taxes accurately. In Spring Licensing Group, Inc. v. New Jersey… – Continue reading

Taxing multinationals: Patently problematic

Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading

LUXEMBOURG: CERTIFICATES OF TAX RESIDENCE, COLLECTIVE INVESTMENTS

The Luxembourg tax authorities issued a circular providing guidance and rules for issuing certificates of tax residence and access to application of income tax treaty provisions for the avoidance of double taxation for Luxembourg “undertakings for collective investment” or UCIs. The circular sets forth guidance for SICAVs / SICAFs and… – Continue reading

Foreign companies with no permanent base may get Minimum Alternate Tax relief

Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading

Government decides to revise convention of double taxation

Pakistan has decided to revise obsolete convention of double taxation and provision of fiscal evasion convention with the United State of America (USA) aimed at bringing the treaty at par with neighbouring countries, well informed sources told Business Recorder. Pakistan and US signed a convention on the avoidance of double… – Continue reading

Taiwan, Japan deal on double taxation avoidance close: official

Taipei, Aug. 27 (CNA) Taiwan and Japan have nearly completed negotiations on a bilateral agreement to avoid double taxation, a Taiwanese official said Thursday. The date of its signing is still being discussed, the official said. The negotiations on the agreement have almost been concluded, Chou Shyue-yow (周學佑), deputy director-general… – Continue reading