Category: Double Taxation

Cyprus and UK sign updated Convention on the Elimination of Double Taxation

The Republic of Cyprus and the Government of the United Kingdom of Great Britain and Northern Ireland, signed on March 22, in Nicosia, an updated Convention on the Elimination of Double Taxation with respect to Taxes on Income and on Capital Earnings and the Prevention of Tax Evasion of tax… – Continue reading

Malta Backs EU Crackdown On Aggressive Tax Planning

Malta has reiterated its commitment to fighting aggressive tax planning, joining other EU member states who have unanimously agreed to amend the EU’s tax information sharing law, the Directive on Administrative Cooperation. The amendments to the Directive, which were agreed last week by EU finance ministers, will require intermediaries, such… – Continue reading

Pakatan’s SST Will Not Relieve People’s Burden, Senseless For The Future

Pakatan Harapan had unveiled an election manifesto earlier this month stating that they will restore the Sales and Service Tax (SST) after abolishing the Goods and Services Tax (GST) within the first 100 days of its administration. While the Prime Minister had pointed out earlier that Malaysia will only be… – Continue reading

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying… – Continue reading

Bangladesh, Morocco sign deal on avoidance of double taxation

In a meeting, both sides agreed to strengthen bilateral cooperation in the areas of economic development, trade and investment, agriculture and tourism cooperation Bangladesh and Morocco have signed an agreement on avoidance of double taxation and a protocol on Foreign Office Consultations. The two instruments were signed by Foreign Minister… – Continue reading

Dutch Cabinet Approves Anti-Evasion Measures

The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – Continue reading

AGREEMENT TO AVOID DOUBLE TAXATION ON MACAU AND TAIWAN AVIATION INDUSTRY

The agreement to avoid double taxation on the aviation industry across Macau and Taiwan came into effect in the second week of February. The Chief Executive signed a notice, which was published in the government’s Official Gazette, notifying the implementation of the memorandum. The notice remarks on how the implementation… – Continue reading

China’s Anti-tax Avoidance Rules

The general anti-avoidance rule was first introduced in China under the 2008 CIT Law. It empowers Chinese tax authorities to make reasonable adjustments where an enterprise implements an arrangement without reasonable business purposes in order to reduce its taxable income or profit. According to the CIT Law’s Implementation Guidelines, “an… – Continue reading

India, Iran ink pact to avoid double taxation, prevent fiscal evasion

India and Iran today signed an agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with regard to taxes on income. The agreement is on similar lines as entered into by India with other countries, the Central Board of Direct Taxes (CBDT) said in a statement. “The agreement… – Continue reading

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime…. – Continue reading

Kazakhstan ratifies amendments to double taxation convention with India

ASTANA. KAZINFORM Kazakhstan has ratified the Protocol between the Governments of Kazakhstan and India on introducing amendments to the Convention on the avoidance of double taxation, the press service of Akorda reports. Head of State Nursultan Nazarbayev signed the Law of the Republic of Kazakhstan “On Ratification of the Protocol… – Continue reading

Sherman Secures Treasury’s Commitment to Pursue U.S.-Armenia Double Tax Treaty

Secretary Mnuchin Commits During Congressional Testimony to Assign Treasury Department Officials to Work on Bilateral Accord WASHINGTON—Treasury Secretary Steven Mnuchin, during Congressional testimony Tuesday before the U.S. House Financial Services Committee, agreed – in response to direct questioning by Representative Brad Sherman (D-CA) – to commit Treasury Department officials to… – Continue reading

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading

European Union removes UAE from tax haven blacklist

UAE was confident of swift removal from the tax haven list in 2018. The UAE, along with seven other countries, has been removed from the European Union’s list of Uncooperative Tax Havens as the country further enhanced its transparency in tax procedures. As a mark of strengthening ties with EU… – Continue reading

Jamaica, Italy sign elimination of double taxation agreement

KINGSTON, Jamaica (JIS) — The Government of Jamaica has signed an agreement with the Republic of Italy for the elimination of double taxation with respect to taxes on income and for the prevention of tax evasion and avoidance. The signing took place at the Ministry of Finance and Public Service’s… – Continue reading

Transfer Pricing Dispute Resolutions in India: New Relaxations

The Income Tax Department recently released a clarification stating that it would accept requests for mutual agreement procedures (MAPs) and bilateral advance pricing agreements (BAPAs) in transfer pricing disputes with all countries regardless of the existence of specific provisions in the Double Taxation Avoidance Agreements (DTAAs). A 2012 survey by… – Continue reading

Taxation agreement with Singapore in effect

The double tax avoidance agreement (DTA) between Cambodia and Singapore came into effect this month, helping clarify taxation rights on all forms of income arising from cross-border business activities, while minimising double taxation. On January 1 the Inland Revenue Authority of Singapore (IRAS) issued an announcement stating that the DTA… – Continue reading

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended… – Continue reading

US tax reform breaks global rules, EU says

European finance ministers are worried. They say the United States’ big tax reform bill contains measures that would unfairly disadvantage European business and contravene global fair-taxation rules. Are they right? Last week, the finance ministers of Europe’s five biggest economies — Germany, France, the UK, Spain and Italy — wrote… – Continue reading

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice… – Continue reading

AmCham EU Speaks Out Against EU Digital Tax Proposals

The American Chamber of Commerce in the European Union has criticized the proposals put forward in the European Commission’s recent consultation on options for new tax rules or a new tax on digital firms. The aim of that consultation is to help the Commission to define an approach to the… – Continue reading

Pakistan, Hong Kong ratify treaty to avoid double taxation

ISLAMABAD: Pakistan and Hong Kong on Monday ratified a treaty signed early this year to stave off double taxation on incomes of their individuals and companies. “Pakistan and Hong Kong SAR (special administrative region) have ratified the avoidance of double taxation and prevention of fiscal evasion with respect to taxes… – Continue reading

Belarus-Hong Kong double taxation agreement comes into force

MINSK, 4 December (BelTA) – The double taxation agreement between Belarus and Hong Kong, a special administrative region of China, has come into effect, BelTA learned from the Belarusian Embassy in Beijing. “After Belarus and China went through the necessary domestic procedures, the Belarus-Hong Kong agreement on the avoidance of… – Continue reading

OECD statistics show 20% increase in outstanding tax treaty disputes involving UK

The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading

NA passes Bhutan-Bangladesh double tax avoidance agreement

The National Assembly endorsed the double taxation avoidance agreement between Bhutan and Bangladesh yesterday. Signed during the visit of Bangladesh Prime Minister Sheikh Hasina to Bhutan in April 2017, the agreement plans to do away with double taxation of incomes between the two countries. In the presence of 38 MPs,… – Continue reading

East African states to ratify double taxation treaty to boost integration

NAIROBI, Nov. 16 (Xinhua) — The East African Community (EAC) member states are set to ratify the avoidance of double taxation treaty in order to boost regional integration, a Kenyan official said on Thursday. Barrack Ndegwa, Regional Integration Secretary in the Ministry of EAC, Labor and Social Protection, told Xinhua… – Continue reading

Govt. of India and Govt. of NZ signs Third Protocol to the Convention for avoidance of double taxation and the prevention of fiscal evasion

The Ministry of Finance (Department of Revenue) vide notification S.O. 3512(E) dated November 2, 2017 sets out the Third Protocol to the Convention between the Government of the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with… – Continue reading

Cabinet Gives Nod To Signing Double Taxation Avoidance Agreement With Hong Kong

The Cabinet today gave its green light to an agreement between India and the Hong Kong Special Administrative Region (HKSAR) of China for avoiding double taxation and prevention of tax evasion. The Cabinet, chaired by Prime Minister Narendra Modi also approved the protocol amending the agreement between India and Kyrgyzstan… – Continue reading

Jersey, Guernsey and Isle of Man join commitment to tackle tax evasion

The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The… – Continue reading

EU Framework for resolving double tax disputes

The EU Economic and Financial Affairs Council has adopted a Directive to create a new system to resolve double taxation disputes between EU Member States. This measure will afford taxpayers a transparent process with clear deadlines applicable to tax authorities involved to resolve cross-border double tax disputes within the EU…. – Continue reading

Double Taxation Agreement Between Barbados and Italy In Effect

BRIDGETOWN, Barbados, Thursday November 2, 2017 – The Double Taxation Agreement (DTA) between the Government of Barbados and the Italian Republic has entered into force. The instruments of ratification for the Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion… – Continue reading

Turkey: Turkey Updates Rules On Double Taxation Prevention Treaties For Independent Professional Services

Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the… – Continue reading

Japan’s National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which… – Continue reading

Google loses 6 year battle, must pay tax on remittances made to Google Ireland

Bad news for the world’s favourite search engine. On Tuesday, the Indian tax office gained an upper hand in its six-year-long battle with Google India in a ruling that would set a precedence for some of the other multinational companies. The rift owes its origin to the arrangement and fund… – Continue reading

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading

New Japan-Denmark DTA To Waive Cross-Border Tax

The Japanese and Danish governments announced on October 11 that they had signed a new agreement for the avoidance of double taxation in Tokyo. The Japanese Ministry of Finance said: “This Convention wholly amends the existing Convention, which entered into force in 1968, by revising the taxation on business profits,… – Continue reading

Ireland Updates International Tax Strategy

The Irish Government has published an updated version of its International Tax Strategy, which provides an overview of the steps taken to meet international standards and sets out the Government’s position on global reform efforts. In his foreword to the Tax Strategy paper, Finance Minister Paschal Donohoe said: “In Ireland… – Continue reading

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding… – Continue reading

New Private Tax Ruling Clarifies the Conditions for New Immigrants to Obtain an Israeli Residency Certificate

Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not… – Continue reading

Inland Revenue Ordinance to be amended to facilitate international tax co-operation

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 5) Bill 2017 (Amendment Bill) was gazetted today (October 6). The Amendment Bill seeks to pave the way for Hong Kong’s participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and to align the Inland Revenue Ordinance (IRO)… – Continue reading

UAE, Costa Rica sign two agreements on encouraging investment, avoidance of double taxation

SAN JOSE- Manuel A. Gonzalez Sanz, Costa Rica‘s Minister of Foreign Affairs and Worship, has met with Mohammed Sharaf Al Hashemi, Assistant Minister of Foreign Affairs and International Cooperation for Economic and Commercial Affairs, at the ministry in capital San Jose. During the meeting, the UAE and Costa Rica signed… – Continue reading

Russia and Japan sign Double Taxation Avoidance Convention

The Russian President and the Japanese Prime Minister signed the Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (the “Convention”) on 7 September 2017. The Convention will replace the existing treaty signed in 1986 by the Soviet… – Continue reading