Category: Double Taxation

EU eyes corporate rules shake-up with law on seat transfer

The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for… – Continue reading

Foreigners in Sri Lanka Treasury bonds may not have to pay tax

ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading

Armenia insists on signing double taxation agreement with USA

YEREVAN, September 25. /ARKA/. Until 2022 Armenia will conclude agreements on the exclusion of double taxation with 8 more countries and will pursue an agreement also with the United States to abolish double taxation, Armenian finance minister Vardan Aramyan said at a press conference on Monday. So far Armenia has… – Continue reading

Hong Kong to examine tax concessions to attract global funds, Financial Secretary says

Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the… – Continue reading

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading

Japan, Russia Agree New Double Tax Pact

The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading

U.S. not going to abolish double taxation with Armenia: envoy

PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a… – Continue reading

Protocol Amending the Mexico-Belgium Tax Treaty Published

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion (“Tax Treaty”) between Belgium and Mexico was published in Mexico’s Official Journal of the Federation (Belgium publication pending). The Tax Treaty became effective in Belgium on August… – Continue reading

Panama: Panama Tax Treaties

The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading

UK: The UK Company: A Tax-Efficient Business Vehicle For International Investors

This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading

New Zealand Moving Forward With Tax Treaty Amendments

The New Zealand Government has announced the signature of two Orders of Council that will implement amendments to its tax treaty arrangements with India and San Marino. The third protocol to the double tax agreement (DTA) with India updates the information exchange provisions and inserts an article on assistance in… – Continue reading

PH to sign tax pact with Brunei

The Philippines is set to sign a double taxation agreement (DTA) with Brunei while eyeing to start negotiations with three other Asean countries as part of its commitments under the regional integration framework. Internal Revenue Assistant Commissioner Marissa O. Cabreros told the Inquirer yesterday that the Philippines’ DTA with Brunei… – Continue reading

Tax revision unlikely to pressure foreign investors, but shocks may persist: analysts

Stock analysts in South Korea played down the possible impact of the government’s decision Wednesday to impose taxes on foreign investors holding over 5 percent of a company, but warned of widening volatility prompted by foreign investors’ sell-offs over the past couple of weeks. Starting January 2018, a broader scope… – Continue reading

Nigeria, Singapore sign agreement to curb double taxation

Nigeria’s federal government on Wednesday signed an agreement with Singapore that would help companies operating in the two countries avoid double taxation in their different bases. The agreement clearly spells out taxing rights of the two countries in respect of different incomes derived from each country. It will specifically assist… – Continue reading

New I-T rules may lead to double taxation, circumstantial valuation difficulties for share transfer

The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading

Irish FinMin Considers Impact Of Brexit On Taxes

As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading

Bankers in Lebanon cry foul over ‘double taxation,’ look to President

BEIRUT: The Association of Banks in Lebanon and other private sector leaders are weighing the few options open to them as recently approved new tax measures, poised to be implemented soon, threaten to have a detrimental effect on their businesses and the overall economy. The few available options include trying… – Continue reading

Kingdom, Brunei pen agreement over taxes

Cambodia signed a double taxation agreement (DTA) with Brunei aimed at preventing dual taxation and fiscal evasion, the Ministry of Economy and Finance said yesterday in a press release. This is the third DTA agreement that Cambodia has signed after Singapore and China, while the government is currently developing framework… – Continue reading

Push to draw up Cambodia-Thai tax treaty

Representatives from the tax authorities of Cambodia and Thailand have agreed in principle to speed up a proposed double taxation agreement that would protect their nationals from dual taxation and encourage bilateral investment. The agreement was made last week during a two-day consultation workshop in Bangkok for tax officials from… – Continue reading

UAE signs avoidance of double taxation deal with Cameroon

The UAE Ministry of Finance (MoF) signed a final agreement for the avoidance of double taxation with the Republic of Cameroon at the Ministry’s premises in Dubai today. The agreement comes in line with the ministry’s strategy to strengthen bilateral trade and economic relations between the two countries, in order… – Continue reading

Ecuador endorses double taxation agreement with Belarus

The National Assembly of Ecuador endorsed the agreement on cooperation in taxation with Belarus by a majority vote. The document is meant to avoid double taxation and prevent property and real estate tax evasion. The agreement was endorsed by the Belarusian and Ecuadorian governments in 2016. The Special Permanent Commission… – Continue reading

Enhancing diplomatic and economic ties: Ghana-Czech Republic Double Tax Agreement to come into force in 2018

Ghana signed another Double Tax Agreement (DTA) with the Czech Republic on 11 April, 2017. Ghana already has DTAs in force with Denmark, the United Kingdom, Belgium, Italy, South Africa, Switzerland, Netherlands, France and Germany. DTAs with Mauritius, Singapore and the Czech Republic are in the process of being ratified… – Continue reading

Australia Changes Tax Stance on Employee Share Schemes

The Australian Taxation Office has reversed its stance on the tax treatment of trustee dividend-equivalent payments to participants in employee share schemes. The ATO’s June 8 draft guidance, Draft determination TD 2017/D2, deals with circumstances in which an employer establishes a trust to provide shares to employees under an employee… – Continue reading

Australia Rejects Double Taxation On Digital Currencies After July 1, 2017

The Government of Australia has announced it is taking steps to become a global financial services leader by loosening a number of policy standards. One includes removing the double tax that currently implemented on digital currencies. The Australian Government has announced it will no longer be imposing a double tax… – Continue reading

OECD Seeks Taxpayer Input On BEPS Action 14 Peer Reviews

The OECD is seeking taxpayers’ input on the mutual agreement procedure (MAP) frameworks in place in the third batch of countries that will now be peer reviewed under Action 14 of the OECD’s base erosion and profit shifting Action Plan: the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and… – Continue reading

Funds Industry Fears BEPS ‘Substance’ Changes

Tax experts have highlighted the increasing importance of substance in the fund management sector in view of the OECD’s base erosion and profit shifting (BEPS) project recommendations. The OECD’s recommendations, among other things, aim to realign taxation with economic substance and value creation, while preventing double taxation. Speaking at the… – Continue reading

PH, Mexico meet anew on trade cooperation

THE Philippines and Mexico have discussed new ways to further improve trade and investment cooperation, and avoid incidents of double taxation, the Department of Finance (DoF) said. A recent meeting between Finance Secretary Carlos Dominguez 3rd and Mexican Ambassador to Manila Julio Camarena Villaseñor focused on Mexico’s concerns regarding a… – Continue reading

Kosovo, Switzerland sign agreement on double taxation

Kosovo and Switzerland signed on Friday an agreement regulating taxation of income and capital, which is beneficial for both countries, the Swiss federal government said. Under the agreement on double taxation dividends will be taxed at source at a maximum rate of 15%, while qualified participations – at no more… – Continue reading