Category: DTA

Recourse to MAP and bilateral APA rollback available under revised tax treaty: PwC

MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning...

Pakistan, Switzerland to sign agreement for bank account information exchange: Dar

Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable...

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...

Common reporting standard: Implementation in Asia

Common reporting standard: Implementation in Asia The Common Reporting Standard (“CRS”) is an internationally agreed standard for automatic exchange of financial account information (“AEOI”) on financial account information, endorsed by the OECD and the Global Forum for Transparency and Exchange of Information for Tax Purposes. The CRS framework requires financial...

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,...

UK, Colombia In Double Tax Deal

The UK and Colombia signed a double tax agreement (DTA) on November 2, which is intended to support trade and investment by capping withholding tax on cross-border income. The agreement was signed by the Financial Secretary to the Treasury, Jane Ellison, and the Colombian Finance Minister, Mauricio Cardenas, during President...

PH eyes tax treaties with Asean peers

The Philippines is eyeing to seal tax treaties with all nine other Asean member-states, according to the Bureau of Internal Revenue (BIR). The country already has effective double taxation agreements (DTAs) with Indonesia, Malaysia, Singapore, Thailand and Vietnam, BIR Assistant Commissioner Marissa O. Cabreros noted in a presentation at last...

India-Korea DTAA notified, capital gains to be taxed at source

India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains...

Georgia-Kyrgyzstan sign agreement on double taxation

Georgia and Kyrgyzstan are increasing economic cooperation by signing an agreement on avoidance of double taxation. The deal was signed today in Georgia’s capital Tbilisi and will prevent people or businesses working between the two countries from evading income and capital taxes. Double taxation is the levying of tax by...

Saudi joins talks on VAT, selective tax in GCC states

The Saudi Council of Ministers has authorized minister of finance or his deputy to discuss two draft uniform agreements on value added tax (VAT) and selective tax for Gulf Cooperation Council (GCC) states. The agreements shall be discussed within the framework of the GCC financial and economic committee, and sign...

Singapore wants to delay revision of tax treaty with India

Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into...

Mauritius seeks India’s help, post tax treaty revision

Mauritius, the island nation that accounts for the second-largest FDI, has sought a line of credit and more investments from India as it gets ready for implementation of the revised tax treaty from April 2017. Mauritian Minister of Finance and Economic Development Pravind Kumar Jugnauth yesterday met Finance Minister Arun Jaitley...

India, Mauritius to discuss revival of FTA, two-way investments today

Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way...

Panama Papers: IT Department invokes tax treaties, sends 200 requests for data on Indians implicated

Officials said around 192 requests had been sent to a number of countries, while another dozen were being processed as part of their investigation. The Income Tax Department on Sunday said it had invoked several tax information treaties and made around 200 requests to collect banking- and finance-related evidence on...

Singapore-Africa trade relations set to deepen with new agreements

Trade relations between Singapore and Africa are set to deepen, with several agreements signed on Wednesday (Aug 24) at the fourth edition of the Africa Singapore Business Forum. These include the signing of the Avoidance of Double Taxation (DTA) with Ethiopia, a bilateral investment treaty (BIT) with Mozambique and an...

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been...

India notifies capital gains exemption norms for Mauritius investors

Private equity (PE) investors and venture capital (VC) funds from Mauritius will have to pay capital gains tax on investments into quasi-equity in India, under the revised tax treaty, unless the conversion of investments into equity is not finalised before 1 April 2017. The government has notified the revised double...

Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection

Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection   The long-awaited Comprehensive Double Taxation Agreement (CDTA) between Hong Kong and Russia entered into force on July 29, 2016. The agreement will take effect on April 1, 2017 in Hong Kong and January...

«Delaware» Crackdown: All Bark and No Bite?

The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a...

A Talk on the Benefits of Double Taxation Avoidance Agreement between Cambodia and Singapore

In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are...

Equalisation Levy seeks to cast Indian tax net wider

Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation...

India, Cyprus finalise DTAA; capital gains to be taxed at source country

India and Cyprus have reached an in-principle agreement on all pending issues on Double Taxation Avoidance Agreement, including taxation of capital gains, which once implemented would help remove the island-nation from a non-cooperative jurisdiction for income tax purposes. An official level meeting between India and Cyprus in New Delhi last...

IRS inversion rules face blowback

A regulatory effort by the Obama administration to crack down on tax deals is facing backlash from business groups and lawmakers on both sides of the aisle. While the Internal Revenue Service (IRS) rules were intended to combat inversions — transactions in which a U.S. company combines with a foreign...

GAAR not to apply on income from investments before April 1

The industry has been demanding that GAAR provisions should apply prospectively To clear the air on retrospective applicability of the stringent anti-avoidance GAAR rule, the I-T department has said the same will not apply to income from transfer of investments before April 1, 2017. General Anti-Avoidance Rule (GAAR), which will...

Netherlands And Switzerland Clarify DTA Fund Treatment

The Netherlands and Switzerland have signed an agreement clarifying the tax treatment of certain collective investment vehicles (CIVs) in each jurisdiction under their bilateral double tax avoidance agreement. The Competent Authority Agreement was signed on June 8, 2016, and deals with the application of the 2010 Dutch-Swiss double tax treaty...

Mauritius pact: A laudable reform

Last month the government announced an amendment to the Double Tax Avoidance Agreement between India and Mauritius. The DTAA was signed between the two countries in August 1982 and notified in December 1983. For the past thirty-three years it has been a key factor affecting foreign investment flows into India....

Cyprus agrees to amend tax treaty ahead of GAAR with caveat

Ahead of India’s rolling out of anti-tax avoidance regulations, Cyprus has shown eagerness to amend the bilateral tax treaty allowing New Delhi to tax capital gains. In turn, has pitched to be taken off the blacklist or being considered a “notified jurisdiction” for not sharing tax information, which implies increased...

Global Tax Update – June 2016

Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from...

Singapore, Cambodia Sign Tax Treaty

Singapore and Cambodia have entered into a double taxation avoidance agreement to boost cross-border trade and investment between the two countries. The Agreement was signed on May 20, 2016, by Indranee Rajah, Singapore’s Senior Minister of State for Law and Finance, and Aun Pornmoniroth, Cambodia’s Senior Minister of Economy and...

GAAR to override bilateral tax treaty provisions: Official

New Delhi, May 11 (IANS) Following the revision of India’s bilateral tax treaty with Mauritius, the government on Wednesday said the General Anti-Avoidance Rule (GAAR ) provisions, with effect from April next year, will override the Double TaxationAvoidance Agreement (DTAA) in case of abuse. “GAAR being anti-abuse provision can prevail...

Who gains, who loses in new tax pact with Mauritius? Will FIIs run away?

India and Mauritius have signed a protocol amending the double tax avoidance arrangement between the two countries. The protocol is the outcome of an extensive and long-drawn-out negotiation process that has been going for more than a year and a half. While the text of the protocol is yet to...

Canada Revenue Agency’s 2014-2015 annual report to Parliament: Focus on compliance measures

The Canada Revenue Agency (“CRA”) released its Annual Report to Parliament (“Report”), outlining the CRA’s performance and key statistics for 2014-2015. This article highlights some of the measures that the CRA has undertaken to combat non-compliance. During 2014-2015, the CRA assessed over $1.7 billion in additional taxes owing and identified...

Govt negotiating issues relating to DTAA with Mauritius

Outstanding issues relating to the existing Double Taxation Avoidance Agreement (DTAA) are under negotiation between India and Mauritius through the mechanism of Joint Working Group (JWG), Parliament was informed today. “India has proposed changes in the existing DTAA to address concerns relating to treaty abuse, around tripping of funds, double...