Category: Double Taxation

Guernsey meets the global tax challenges

The implementation of stricter taxation scrutiny globally shows no sign of abating. Nonetheless, Guernsey is well-placed to meet many of these challenges, and indeed thrive in this new world order. Guernsey has repeatedly demonstrated an ability to comply with international obligations and adapt to challenges and changing circumstances and the… – Continue reading

The intersection of US tax treaty policy, tax reform and BEPS

Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading

Khalifa ratifies UAE agreements

ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading

Japan and the UK exchange notes concerning article 7 (“business profits”) of the Japan-UK Tax Convention

On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland… – Continue reading

New Scotland bill – tax implications

The UK Government has published draft legislation on devolving certain tax matters to Scotland (the Bill). It intends that the draft legislation should implement the terms of the devolution agreement made in November 2014 between the Westminster and Holyrood governments. Having looked over the Bill, it appears that the Scottish… – Continue reading

Cabo Verde and Guinea-Bissau sign agreement to avoid double taxation

The governments of Guinea-Bissau and Cabo Verde (Cape Verde) signed agreements to avoid double taxation and prevent tax evasion at the end of a four-day working visit to Guinea-Bissau by the Prime Minister of Cabo Verde, José Maria Neves. Alongside the tax agreement, Cabo Verde will train Guinean technicians so… – Continue reading

News Analysis: Long way to go for harmonized corporate tax policies within EU

THE HAUGE, July 20 (Xinhua) — The Dutch-German agreement to enhance the exchange of information on tax rulings was “an important step” towards greater transparency, but there is still a long way to go before reaching common ground on harmonized corporate tax policies within the European Union (EU), according to… – Continue reading

New online service to help recover tax paid on share dividends abroad

Irish people investing in other countries often lose up to a fifth of dividends Irish tax refund specialists Taxback. com have introduced an online service to help people recover tax withheld on share dividends in other countries. *Irish people investing abroad often lose up to a fifth of their dividends… – Continue reading

British trade boost: How UK firms profit from Middle East commerce

Lord Sieff, then head of food at Marks and Spencer, returned from 1950s Israel having inked an agreement with horticulturalist Gordon Bickel to buy his gypsophila spray carnation. More than half a century later Bickel’s firm, Carmel Agrexco, has expanded from what he calls the ‘white gold’ that was behind… – Continue reading

Brunei, Luxembourg sign pact on taxation

AN AGREEMENT to avoid double taxation and prevent tax evasion has been signed between Brunei and Luxembourg last Tuesday in Brussels, the Ministry of Finance (MoF) said yesterday. The MoF said this is in line with Brunei’s commitment to implement an internationally agreed tax information exchange standards. The ministry said… – Continue reading

Cross-border action raises tax risks

The rising exchange of information between countries is also leading to the disclosure of more details about these taxpayers’ affairs. Along with other countries, SA is paying closer attention to its residents’ cross-border activities. But while compliance is necessary, industry experts warn that overly aggressive tax enforcement in SA could… – Continue reading

GAAR provision to make way into India-Mauritius treaty

India and Mauritius are set to limit the benefits of their double tax avoidance agreement (DTAA) to only genuine businesses bringing foreign direct investment to India by inserting a new clause in the treaty straight from New Delhi’s yet to be implemented General Anti-Avoidance Rules (GAAR). The revised treaty, however,… – Continue reading

Cyprus: The Cyprus Intellectual Property Rights ‘Box’ – A Limited Time Opportunity

In May 2012, Cyprus introduced a package of incentives and tax exemptions relating to investment in intellectual property rights, commonly known as an “IP box.” Intellectual property projects are particularly susceptible to cross-border planning by reason of the mobility of intellectual property rights, which do not consist of physical assets… – Continue reading

Critical Factors in Handling Italian Transfer Pricing Controversies

In response to the economic downturn and the growing need for tax revenues, the Italian Tax Authorities (ITA), like authorities in many other jurisdictions, have more aggressively targeted multinationals and their tax planning strategies in recent years, resulting in more domestic and international tax controversies. Transfer pricing (TP) issues account… – Continue reading

Bulgaria cabinet approved agreement with Romania on double taxation avoidance

Sofia. Bulgarian government approved the agreement between Bulgaria and Romania on the double taxation avoidance and prevention of tax concealing, inked in April 2015, the press office of the Bulgarian Council of Ministers announced. The document is filed for ratification by the parliament. The current agreement between the countries was… – Continue reading

India: Recent Developments Regarding Minimum Alternative Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading

Modi government may soon clarify tax rules for permanent establishment

MUMBAI: The government may soon clarify tax rules making it easier for fund managers operating large India-dedicated funds to set up an office in the country, four months after finance minister Arun Jaitley announced in the budget about the government’s intentions to do so. The finance ministry and the central… – Continue reading

Big changes to India-Mauritius DTAA?

Mauritius’ former finance minister claims that his country has given up the right to tax capital gains. This has raised questions regarding the scope of the renegotiation of the India-Mauritius Double Tax Avoidance Treaty (DTAA) Former finance minister of Mauritius says renegotiated tax treaty with India will have devastating effect… – Continue reading

Alex Malley: Key goes in to bat for imputation credits

The Government’s submission to the “Re:think” tax white paper process under way in Australia highlights the lack of mutual recognition of imputation credits as the most significant barrier to a seamless transtasman market and calls for visionary political leadership. Prime Minister John Key displays the very leadership he’s calling for,… – Continue reading

Double taxation in the AEC and tax credits in Thailand

The long-awaited formation of the Asean Economic Community (AEC) is just over five months away. Drawn by the promise of a freer flow of goods, services, investment, capital and skilled labour, many businesses need to study how to prevent or reduce the effects of double taxation. Double taxation results from… – Continue reading

Your Taxes: The draft transparency law

A draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax information-sharing agreements. The Israel Tax Authority (ITA) has just circulated a draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax… – Continue reading

‘Google tax’ – a step into the unknown

Special Business News article by Rob Rotherham, KPMG tax division senior manager, on the effects of the UK Budget. With effect from April 1, 2015, the UK Government introduced a new tax: the Diverted Profits Tax. (DPT). The DPT is aimed at countering the use of aggressive tax planning techniques… – Continue reading

His Majesty issues two Royal Decrees

Muscat: His Majesty Sultan Qaboos Bin Said today issued two Royal Decrees as follows: Royal Decree No. 30/2015 establishes Oman Governance and Sustainability Centre and promulgates its bylaw. Article (1) states that a centre to be named “Oman Governance and Sustainability Centre” shall be set up and affiliated to the… – Continue reading

Vietnam: FIRST EVER Double Taxation Agreement Signed Between Vietnam And The United States Of America

On 07th July 2015, the United States and Vietnam signed an income tax treaty with Vietnam, the first ever between the two countries. The Double Taxation Agreement applies to personal income tax and enterprise income tax in the case of Vietnam. What is a permanent establishment? Under the Double Taxation… – Continue reading

Jaresko: Ukraine, Cyprus agree to revise taxation agreement

Ukraine and Cyprus have agreed to review bilateral agreements on taxation to prevent the withdrawal of capital to offshore zones, Finance Minister Natalie Jaresko wrote on Facebook. “After very lengthy negotiations, we’ve finally taken an important step in the fight against capital withdrawal to offshore zones: we have with the… – Continue reading

Lisbon treaty: Technical briefing with NDR

Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading

Key pillar of the Beps process is to align profit with value creation

OECD guidance needs to be clear otherwise the process could favour the bigger nations In Paris last week, as Angela Merkel and Francois Hollande discussed events in Greece, the international tax system was being discussed in an underground meeting room at OECD headquarters. For almost two days tax authority delegates… – Continue reading

India: recent developments regarding Minimum Alternate Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading

Uzbekistan, Belgium to exchange tax info

Uzbekistan’s President Islam Karimov has signed a protocol to make amendments to Uzbek-Belgian convention on avoidance of double taxation and prevention of tax evasion on income and capital. Uzbek president’s decree “On approving the international agreement” published in the local media July 13, approves the amendments to the convention of… – Continue reading

Want to open an overseas bank account? It’s a bit harder than you might expect

The continuing speculation over Greece’s possible exit from the Eurozone and the weakening effect this might have on the shared currency in the short-term, may once again be prompting some folks to consider setting up non-resident bank accounts in non-eurozone countries. Offshore banking has a bit of a dodgy image… – Continue reading

Tanzania: Double Taxation Agreements Support Investors

One of the most immediate and obvious consequences of globalisation is the impact of domestic tax policies in other countries on the economy of Tanzania. This has necessitated the continuous evaluation of the tax regime in Tanzania and brought about crucial fiscal and economic reforms in the country. Hence, the… – Continue reading

Negotiations on DTAA between India and Mauritius in advanced stages: Revenue Secretary

Finance Ministry has informed that the negotiations on the double taxation avoidance agreement (DTAA) between India and Mauritius are in advanced stage and the pact would be revised soon. Revenue Secretary Shaktikanta Das has said that “DTAA treaty (with Mauritius) is in very advanced stage of negotiation. It is progressing… – Continue reading

Swiss Poised To Support Greek Tax Amnesty

Swiss Poised To Support Greek Tax Amnesty by Matthew Allen, swissinfo.ch Struggling to pay off more than €300 billion (CHF313 billion) in debts, Greece is banking on Switzerland to help it recover a treasure trove of undeclared assets that tax cheats have stashed in alpine vaults. But anti-tax haven campaigners… – Continue reading