Category: Double Taxation

Helpful For Shipping Industry

Double Taxation Avoidance Agreement Amended between S. Korea and India The Korea Shipowners’ Association announced on January 24 that the Double Taxation Avoidance Agreement between South Korea and India was amended so that South Korean shipping companies’ shipping income generated as a result of their maritime transport services provided for… – Continue reading

New tax regime for Ukrainian loan participation notes issued on international capital markets

January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic… – Continue reading

Latvia and Japan sign agreement intended to promote investment and make investors’ work easier

RIGA – Latvian Finance Minister Dana Reizniece-Ozola (Greens/Farmers) and Motome Takisawa, Parliamentary Vice-Minister for Foreign Affairs of Japan, today signed a convention for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, BNS was told at the Finance Ministry. The… – Continue reading

New Double Tax Treaty signed between Montenegro and Portugal

Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income… – Continue reading

Israel Tax Authority Deems Bitcoin a Taxable Asset

The Israeli Tax Authority has issued an official draft circular to clarify the tax guidelines that apply to bitcoin adopters. In an announcement last week, the Israel Tax Authority released its draft [PDF] on the proposed taxation of virtual currencies which are considered “assets”. Pointedly, the announcement also cites the… – Continue reading

Belarus, China’s Hong Kong sign double taxation avoidance agreement

Belarus and Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on the avoidance of double taxation and prevention of income and capital tax evasion on 16 January, BelTA learned from the Belarusian embassy in China. Specialists believe that the agreement on the avoidance of… – Continue reading

UK/Uruguay double taxation convention takes effect

The comprehensive Double Taxation Convention between Uruguay and the United Kingdom has taken effect from 1 January 2017. The United Kingdom and Uruguay signed a convention to avoid double taxation and prevent fiscal evasion related to taxes on income and on capital on 24 February 2016 in Montevideo. The document… – Continue reading

In Slovakia, 2017 brings new tax legislation

The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading

Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance

A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Amended tax treaty with the Isle of Man comes into force

The amended double taxation agreement between the UK and the Isle of Man has entered into force, effective from 5 January 2017, following the latest arrangements signed on 8 March 2016. The bilateral agreements between the UK and the Isle of Man concern cooperation in tax matters through the exchange… – Continue reading

Curbs on black money abroad: Govt revising tax treaties to share data with ED, CBI

Sources said this amendment will allow speedy prosecution and imprisonment of account holders as enumerated in the Panama Papers, Liechtenstein and HSBC Geneva lists. Moving to register criminal charges and impose stricter penalties against those who have stashed black money abroad, India has started revising tax treaties with partner countries… – Continue reading

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

Georgia establishes tax free relations with Liechtenstein

Georgia and Liechtenstein are increasing economic cooperation by avoiding double taxation, meaning that people or businesses working between the two countries will be free from income and capital taxes. The deal was signed in May 2015 in Georgia’s capital Tbilisi but entered into force today. Double taxation is the levying… – Continue reading

Government planning action to target multinationals over tax

The Government is planning unilateral action to crack down on tax dodging by multinational companies, including changing the law, amid growing concern about fairness. Revenue Minister Michael Woodhouse said proposals outlined in a cabinet discussion document tabled last month would see Inland Revenue properly armed to tackle the problem and… – Continue reading

PBC urges Dar to ask FBR to go easy on super tax

Pakistan Business Council (PBC) has approached Finance Minister Ishaq Dar to stop the Federal Board of Revenue (FBR) from recovery proceedings of Super Tax against non-resident companies on dividend income from their investments in Pakistan. Sources told Business Recorder here on Tuesday that the PBC has urged the Finance Minister… – Continue reading

Double taxation: Ecuador, Italy sign agreement to foster private investements

Ecuador signed an agreement with Italy to define the tax obligations of the citizens of the two countries, in order to avoid double taxation on income taxes and equity and prevent tax evasion, the Ecuadorian Foreign Ministry said. “This protocol modifies the agreement signed in Ecuador and Italy in 1984… – Continue reading

Ireland Rejects Oxfam’s Tax Haven Claims

Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the… – Continue reading

International taxation changes could ‘pose a major challenge’ to Malta’s iGaming sector

Changes in the way international taxation is collected, thanks to recommendations made by the Organisation for Economic Cooperation and Development (OECD) could “pose a major challenge to the sustainability and profitability” of many iGaming operations in Malta. This information came to light through a report issued by Country Profiler on… – Continue reading

Ukraine: Tax Residency Status: Issues To Consider When Moving Abroad

Recent social and economic developments have had a powerful impact on many Ukrainian citizens and businesses and have led them to look for a better life beyond the borders of Ukraine. Obviously, Ukrainians moving abroad is not something new. Periods of economic crisis in almost every state are usually accompanied… – Continue reading

DOUBLE TAXATION AGREEMENT BETWEEN SWITZERLAND AND OMAN

MUSCAT -The Double Taxation Agreement (DTA) between Switzerland and Oman aiming to increase economic ties officially came into force last month, according to the Swiss government. Its provisions will be applicable from January 1, 2017, according to the government. The agreement was originally signed on May 22, 2015 before going… – Continue reading

Pak-China avoidance of double taxation treaty inked

ISLAMABAD – Pakistan and China signed third protocol to the avoidance of double taxation agreement that would allow a Chinese bank and a state-owned investment fund to avail income tax exemption on interest income from loans for energy projects under China-Pakistan Economic Corridor (CPEC). Federal Board of Revenue (FBR) Chairman… – Continue reading

India, US strike 1st bilateral advance pricing agreement: Government

NEW DELHI: India and the US have reached a deal for the first bilateral advance pricing agreement, a move that will enable American firms to ascertain tax liabilities beforehand, Finance Minister Arun Jaitley said today. The two nations have resolved over 100 cases of tax disputes involving a tax of… – Continue reading

Italy: Italy Set To Introduce A Territorial System Of Taxation

Italy is considering a proposal to introduce a territorial system of taxation to attract high net worth individuals, including successful individuals in the sports, arts, and fashion and design sectors, who could be interested in moving to Italy to take part in these thriving sectors. The new measure is contained… – Continue reading

Putting an end to corporate tax controversy

Controversy over giant corporations paying dwarfed tax bills has put finance chiefs in the media and public spotlight When giant companies with devilishly complex tax arrangements are accused of unethical behaviour, the stock response is “we act within the rules”. If the public and politicians don’t like it, the argument… – Continue reading

ICC welcomes adoption of OECD Multilateral Convention

The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD)’s release last week of a multilateral convention which allows for swift implementation of a series of tax treaty measures encompassed in the OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The release follows the conclusion… – Continue reading

UK – FIRMS RESPOND WITH CONCERN OVER PUBLISHED IR35 PUBLIC SECTOR REFORMS

Draft legislation for the public sector IR35 reforms was published yesterday and several firms have responded concernedly to the publication of the documents. IR35 legislation reforms were proposed recently during the Autumn Statement. Julia Kermode, chief executive of The Freelancer & Contractor Services Association, commented on the publication of the… – Continue reading

Australia’s Google Tax may be the second in the world but it’s too early to tell if it’s the ‘toughest’

When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the… – Continue reading

Tax benefits of using Malta as an IP regime

For myriad reasons, Malta has over the years established itself as an ideal jurisdiction to hold intellectual property rights. The country offers many tax benefits on income derived from Intellectual Property. Apart from the tax exemption on income derived from patents, copyrights and trademarks as will be further explained below,… – Continue reading

DTA with Liechtenstein

The double taxation agreement (DTA) between Switzerland and Liechtenstein will enter into force on 22 December 2016. The DTA contains a provision on the exchange of information upon request according to the internationally applicable standards. The DTA will contribute to the development of good economic relations between Switzerland and Liechtenstein…. – Continue reading

Ukraine officially joins BEPS project

On November 22, 2016, the Minister of Finance of Ukraine handed an official letter on Ukraine’s accession to the BEPS (Base Erosion and Profit Shifting) plan to the Secretary-General of OECD. Being the final stage in the process of joining the project, Ukraine is to become a member of the… – Continue reading

Action Against Tax Evasion/Black Money Is An Ongoing Process: Minister

Minister of State (Finance) Santosh Kumar Gangwar on Tuesday said action against tax evasion/black money, including in respect of black money stashed away abroad, is an ongoing process and such action under direct tax laws includes searches, surveys, enquiries, assessment of income, levy of penalties and filing of prosecution complaints… – Continue reading

India, Cyprus ink new Double Tax Avoidance Agreement

New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,… – Continue reading

Tens of millions of dollars of revenue lost through dodgy trust structures

Just a handful of dodgy tax structures being used by Australians cost tens of millions of dollars in lost revenue, according to the Australian Taxation Office. That could mean many millions more are missing, and is why the ATO is cracking down on people misusing trusts. The agency has long… – Continue reading

SINGAPORE-LAOS AVOIDANCE OF DOUBLE TAXATION AGREEMENT ENTER INTO FORCE

The new Singapore-Lao People’s Democratic Republic Avoidance of Double Taxation Agreement (DTA) entered into force on 11 November 2016. The DTA provides clarity on tax matters and eliminates double taxation relating to cross-border transactions between the two countries. A DTA between Singapore and another jurisdiction serves to prevent double taxation… – Continue reading

Common Base Could End EU Patent Box, Transfer Pricing Disputes

Adoption of legislation for a common consolidated corporate tax base by 27 EU member states would resolve current patent box conflicts and end transfer pricing disputes that cost multinational companies hundreds of millions of dollars in double taxation, according to EU and industry officials. Speaking at a Nov. 15 conference… – Continue reading

Federal government moves to stop double taxation, evasion

The Federal Executive Council, FEC, on Wednesday approved a bilateral agreement for the avoidance of double taxation and the prevention of physical evasion of taxes on income and capital benefits between Nigeria and Singapore. The Minister of Finance, Mrs. Kemi Adeosun disclosed to State House Correspondents, after the FEC meeting… – Continue reading

Dispute resolution under the Nigerian transfer pricing regime

Background The Federal Inland Revenue Service [FIRS] has begun Transfer Pricing [TP] audits and has been requesting TP documentation and other documents from taxpayers relating to their related party transactions. These actions are in line with its powers under the Income Tax (Transfer Pricing) Regulations No. 1 of 2012 [Regulations]… – Continue reading

Labour and unions demand action on temp agencies’ tax avoidance

Opposition vows to shut down scheme that uses ‘contrived’ financial arrangements to slash national insurance bills Labour and trade unions have called on the government to take action after a Guardian investigation found that an aggressive tax avoidance scheme used by temporary recruitment agencies is depriving the taxpayer of “hundreds… – Continue reading

EU Parliament May Lose Right to Veto Public Tax Reporting

The European Parliament risks losing the right to veto plans to make multinational companies publish tax and profit details for the countries in which they operate, according to the European Union’s legal advisers. The Council of Ministers’ legal service insisted in its opinion, seen by Bloomberg BNA, that the European… – Continue reading

To Boost Trade, A Bilateral Tax Treaty Between India And The UK May Be In The Offing

Following British Prime Minister Theresa May’s visit to India last week, Patricia Hewitt, chair of the UK-India Business Council, said that Britain is looking to re-balance its commercial links with countries like India post-Brexit. She suggested that the two governments should look at a bilateral tax treaty to boost trade…. – Continue reading

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs… – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

Hong Kong Pushes For DTA, Info Exchange With Australia

In Canberra, Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, expressed his wish to quickly start negotiations on a comprehensive double taxation agreement (CDTA) with Australia. During his meetings with Australia’s Treasurer, Scott Morrison, and the Minister for Revenue and Financial Services, Kelly O’Dwyer, Chan pointed… – Continue reading

Finnish Expats In Portugal Face Higher Taxes

Finland will have “more possibilities” to tax Finnish pensioners living in Portugal under a recently revised bilateral double taxation avoidance treaty, the Finnish Government has said. The new agreement was signed on November 7 by Portuguese Finance minister Mario Centano and his Finnish counterpart Petteri Orpo, who declared himself “very… – Continue reading