Category: Double Taxation

Italy Ratifies FATCA Agreement with US

Italy has ratified the inter-governmental agreement top facilitate compliance with the United States Foreign Account Tax Compliance Act. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign financial institutions (FFIs) by US persons. Failure by an… – Continue reading

Shah Mehmood Qureshi raps withholding tax

MULTAN: Pakistan Tehreek-i-Insaf (PTI) national organiser Shah Mehmood Qureshi on Tuesday lambasted the imposition of a 0.6 per cent withholding tax on bank transactions. Qureshi was speaking to journalists at the press club. He demanded that the tax to be immediately withdrawn and said the PTI stood with traders on… – Continue reading

Abuse of tax treaties must end

Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading

Dual taxation, fiscal evasion: Finance Act expands scope of agreements

Finance Act 2015 has expanded the scope of the agreements meant for avoidance of double taxation and prevention of fiscal evasion to be executed by the federal government. Explaining the Finance Act 2015, Former FBR Member Habib Fakharuddin said that the federal government may enter into an agreement, bilateral or… – Continue reading

OECD backs Guernsey as a cooperative jurisdiction

The Organisation for Economic Cooperation and Development (OECD) – the leading international standards-setter for tax transparency and cooperation – has underlined Guernsey’s reputation as a cooperative jurisdiction, reports Guernsey Finance. Monica Bhatia, Head of the Secretariat of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading

Muscat: His Majesty Sultan Qaboos bin Said issued two Royal Decrees, as follows:

Royal Decree No. 26/2015 ratifies the Agreement on Delimitation of Maritime Boundaries (Borders) in Sea of Oman between the Sultanate of Oman and the Islamic Republic of Iran, signed in Muscat on May 26, 2015. Article (1) ratifies the above-mentioned Agreement. Article (2) states that this Decree shall be published… – Continue reading

Cabinet to remove Austria from list of risky countries for transfer pricing on August 1, 2015

Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading

Cyprus: Cyprus’s New Double Taxation Agreement With Bahrain

Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading

Bureau van Dijk on the power of information

Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading

ICDS: A double-edged sword for companies

The taxable income might now be visibly de-linked from the accounting income Historically, enterprises have computed taxable income applying profits as per the financial statements as the starting point and making additions or deductions thereto, as required by the Income-tax Act. 1961 (I-T Act) for the purposes of annual income… – Continue reading

MNCs park profit in Singapore, Hong Kong

Calcutta, July 5: Singapore and Hong Kong, with their low corporate tax rates, have started to hove into view on the radars of multinational companies that are looking to lower their tax burdens through profit shifting. Profit shifting is a perfectly legal way of moving the earnings of an MNC… – Continue reading

BIBA: Time to talk tax havens

ARBADOS’ CONTROVERSIAL BLACKLISTING by a group of European Union (EU) countries is “hypocritical” and “grossly discriminatory”, says outgoing Barbados International Business Association (BIBA) president Connie Smith. But Smith also thinks the time is right for “engaging in bilateral discussions which could hopefully conclude in double taxation agreements and bilateral investment… – Continue reading

Ethiopia, Côte d’Ivoire Sign MoU

The Ethiopian Investment Commission and Center for the Promotion of Investments in Cŏte ďIvoire (CEPICI) signed a Memorandum of Understanding (MoU) which would serve as a guideline to augment commercial exchanges,implement joint investment projects and boost economic cooperation among others, between the two countries. Speaking at Ethio-Ivorian Business and Investment… – Continue reading

New Zealand-Canada double tax agreement to help investors

New Zealand-Canada double tax agreement to help investors WELLINGTON, July 2 (Xinhua) — A new double tax agreement between New Zealand and Canada is set to facilitate investment and trade between the two nations, Revenue Minister Todd McClay said Thursday. The new agreement will lower withholding taxes on dividends, interest… – Continue reading

India and Mauritius reach consensus on double taxation avoidance agreement

Mauritius and India have reached consensus in the conclusion of the Double Taxation Avoidance Agreement (DTAA) which has been long awaited between the two countries following fruitful discussions yesterday between joint working groups of Mauritius and India, reports All Africa. The positive conclusion of the negotiations will open a new… – Continue reading

Another Swiss Bank Reaches Resolution under Justice Department’s Swiss Bank Program

Washington, DC—(ENEWSPF)—July 2, 2015. The Department of Justice announced today that Privatbank Von Graffenried AG has reached a resolution under the department’s Swiss Bank The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading

BEPS Action 3: How Not to Engage with CFC Rules

Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading

International tax update – July 2015

OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading

Mexico: Energy Reform – Chapter VI: Implications On International Tax Matters

1. Permanent Establishment 1.1. Subjects and activities that generate a PE Article 64 of the LISH provides that a PE is created whenever ever a resident abroad for tax purposes carries on with activities under the LH in Mexican territory or the exclusive economic zone over which Mexico has jurisdiction…. – Continue reading

Supreme Court says Pendragon’s dealerships accountable after finding demonstrator VAT scheme was “abusive” of the law

The UK’s Supreme Court has ruled that a KPMG scheme to enable dealer group Pendragon to recover VAT on demonstrator cars sold as used cars was “abusive” of the law. Its decision earlier this month has overturned a previous Court of Appeal ruling on the scheme, which Pendragon used on… – Continue reading

Kikwete tells Indians to come over

NEW DELHI, India – Tanzanian President Jakaya Kikwete was recently in New Delhi at the invitation of Indian investors and to drum up more foreign investment for his country The interactive session was attended by several hundred businesspeople and organised by the Confederation of Indian Industries (CII). Kikwete said although… – Continue reading

Pakistan stumps India; rolls out South Asia’s 1st REIT while we still try to axe the tax

MUMBAI: India 0 Vs Pakistan 1. It’s not the outcome of a ODI series between the traditional rivals but a progress card on reforms in the world of real estate. At a time Indian realtors and investors are struggling to roll out real estate investment trusts (REIT) amid regulatory complications… – Continue reading

Tax treaty with Mauritius blocks outflow

A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading

Ethiopia, Brazil Conclude Avoidance of Double Taxation Agreement

Ethiopia and Brazil concluded an agreement for the avoidance of double taxation on profits derived from international air and shipping transport on June 22, 2015 in Brasilia, according to Fana Broadcasting corporate. H.E Ambassador Sinknesh Ejigu, Special Envoy, Ambassador Extra ordinary and plenipotentiary of the Federal Democratic Republic of Ethiopian… – Continue reading

Armenia renews treaty to exempt double taxation with Belarus

YEREVAN. – Armenia has renewed a treaty to exempt double taxation with Belarus during the Cabinet’s meeting on Thursday. In particular, the treaty envisages regulation of the residency of legal entities in the case of dual residency. The procedure for the exchange of information constituting bank secrecy has been specified…. – Continue reading

BEPS IN TROUBLE—GLOVES OFF AT THE OECD CONFERENCE

The verities of international tax law are no more. The days of strong residence-based rules of corporate taxation are numbered. The age of the Permanent Establishment (“PE”) as the central concept of international tax is drawing to a close. That seems to be the message from the OECD International Tax… – Continue reading

Isle of Man: Isle of Man’s TIEA With Italy Now In Force

The Isle of Man’s Agreement for the Exchange of Information Relating to Tax Matters with the Government of the Italian Republic entered into force on 10 June 2015. The agreement was signed on 16 September 2013 in London between Eddie Teare, the Isle of Man’s Treasury Minister, and His Excellency… – Continue reading

Insurance tax changes loom on the horizon

Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading

Hong Kong chides EU for new tax blacklist

Hong Kong’s Government has expressed its regret that the European Union included the territory in its list of non-cooperative tax jurisdictions, saying that criticism of its transparency in tax matters is “totally unfounded.”, reports Tax News. The EU tax blacklist was included in the European Commission’s new Corporate Tax Reform… – Continue reading