Category: Tax treaties

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading

Canada: Taiwan – Canada Tax Arrangement Released

On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading

India, Armenia sign protocol to amend tax pact

India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading

BEPS project: most Indian MNCs see double taxation going up in short term

NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading

Deloitte’s BEPS survey: Quite an eye opener

NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading

S. Korea, Macau to sign tax information exchange agreement

Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading

How to take your UK pension pot overseas-and not be hit by a big tax bill

Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading

Gulf’s proposed 5% VAT may translate into more than 10% hit on net income: EY

The Gulf countries’ proposed 5% value added tax (VAT) may translate as more than a 10% hit on net income, unless tax efficiencies are improved, according to Ernst and Young (EY). “A 5% rate may not sound like a lot, but if it ends up as an additional cost on… – Continue reading

TAX DEPT INKS SEVEN NEW TRANSFER PRICING PACTS

The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading

Redomiciliation of foreign companies

The redomiciliation of companies (ie, movement of a company incorporated in one jurisdiction to another, retaining its legal character) is not recognised under Chilean law. This means that in order to move to Chile, a foreign company must establish a branch or create a subsidiary there. It cannot move its… – Continue reading

Brazil: study abroad exempt from new overseas payment tax

Study abroad programmes will be exempt from a new 25% tax on overseas payments that was announced last week, the Department of Federal Revenue has announced, prompting a sigh of relief among stakeholders that send and receive Brazilian students abroad. The new levy prompted widespread concern in the study abroad… – Continue reading

Federal govt authorised to levy sales tax on entire supply chain, manufacturing’

KARACHI: The Federal Board of Revenue (FBR) has issued a detailed clarification, which clearly defines that the federal government is authorised to levy sales tax on supply and manufacturing of goods, whereas the power to levy sales tax on services have been vested with provinces. The clarification was made in… – Continue reading

Uncompetitive tax?

Generally, if a South African taxpayer sells shares in a foreign company, he will be hit with South African capital gains tax (CGT) on any gain realised on that sale. However, South Africa provides exemptions from this CGT in certain circumstances, one of which relates to the sale of foreign… – Continue reading

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading

The Netherlands implements OECD BEPS Country-by-Country Reporting as well as the amendments to the EU Parent-Subsidiary Directive

As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading

Don’t believe the ‘loopholes’ hype

Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. Unfortunately, these calls are based on outdated numbers and an incomplete picture of the tax system…. – Continue reading

Intl bodies to fight global tax evasion / Maximum of $240 bil. said to be dodged

The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals

The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading

Latest statistics show wealthy already pay more than taxes than other groups

WASHINGTON, D.C.—Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. A few weeks ago, the IRS released new data showing that the average federal individual… – Continue reading

Russian Agreement Advances Hong Kong’s DTA Priorities

Hong Kong’s newly signed double tax deal with Russia is said to support the territory’s ongoing efforts to expand its tax treaty network with jurisdictions along “the Belt and Road.” The Belt and Road, or the Silk Road Economic Belt, is a Chinese Government economic development project, which is primarily… – Continue reading

Budget 2016 may introduce BEPS to make tax evasion difficult for MNCs

MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading

Exclusive: EU plans faster investment tax refunds from 2017 – document

European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading

PROPERTY TAX POST: ROLL OF THE ‘D.I.C.E.’ —BUSINESS PERSONAL PROPERTY TAX RELIEF IS A CRAP SHOOT

Each year, states enact tax law changes and create local government programs that provide personal property tax breaks for businesses. These concessions come in various forms—deductions, incentives, credits and exemptions (i.e., D.I.C.E.), and they have a significant impact on whether businesses remain viable. Many states commonly impose ad valorem tax… – Continue reading

Tax Practice: Applying for Tax Benefits under International Tax Treaties in China

In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading

QROPS – The Great American Pension Nightmare

The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading

Nigeria signs double tax treaty with United Arab Emirates

As part of the ongoing visit by President Muhammadu Buhari to the United Arab Emirates (UAE), both countries today signed six agreements on Trade, Finance and Judicial Matters; Avoidance of Double Taxation; Trade Promotion and Protection; Judicial Agreements on Extradition, Transfer of Sentenced Persons; Mutual Legal Assistance on Criminal Matters;… – Continue reading

SIM cards, handsets: Scheme of taxation legally impermissible, argue CMOs

Three leading cellular operators have made a joint representation to the Federal Board of Revenue (FBR) that the scheme of taxation contemplated by the Ninth Schedule of the Sales Tax Act 1990 in relation to both items – SIM cards and handsets – is legally impermissible and unconstitutional and practically… – Continue reading

Russia, Hong Kong sign avoidance of double taxation agreement

Russia and the Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on avoidance of double taxation and prevention of fiscal evasion regarding profits taxes on Monday. The document was signed by Russia’s State Secretary, Deputy Finance Minister Yuriy Zubarev and the Secretary for Financial… – Continue reading

PoEM not the only solution

The change in definition of an Indian resident company under the Income-Tax Act—from one whose affairs are wholly controlled and managed in India to one whose Place of Effective Management (PoEM) is in India—and the subsequent draft guidelines are giving anxious moments to votaries of simplifying the investment climate in… – Continue reading

COAI submits Budget recommendations to government

The Cellular Operators’ Association of India (COAI) has submitted a budget recommendations to the government which include suggestions on central value added tax (CENVAT) Credit, deductibility of spectrum fees paid and tax withholding on distributors margin on sale of SIM cards and prepaid vouchers among many others. The recommendations said… – Continue reading

Start-up investment in India to get capital gains tax exemption

PM Narendra Modi also announces a Rs.10,000 crore fund to provide support to innovation driven enterprises New Delhi:In an effort to give a fillip to the start-up ecosystem in the country, the government on Saturday announced its intention to exempt capital gains tax on investments in start-ups and a Rs.10,000… – Continue reading

Saudi Arabia third in global ranking for tax payment ease

JEDDAH: Saudi Arabia has maintained third in the global ranking for ease of tax payment, according to the latest release of the Paying Taxes report by the World Bank and PwC. With the least demanding tax framework, well below the world average, the Kingdom has a total tax rate of… – Continue reading

Lake commissioner complains of double taxes

CROWN POINT — Lake County officials are debating whether they have accidentally double taxed Cedar Lake and Schererville residents. Lake County Commissioner Gerry Scheub, D-Crown Point, argues this week a mistake by the County Council in funding the county’s E-911 public safety dispatching service has resulted in Cedar Lake residents… – Continue reading

Budget 2016: Modi government likely to revamp direct taxes to improve ease of doing business

NEW DELHI:The Narendra Modi government, which has pledged a predictable and non-adversarial tax regime, is likely to begin a sweeping revamp of direct taxes in the Budget that Finance Minister Arun Jaitley will present next month. Simplification and rationalisation will be the two themes driving the overhaul, which is aimed… – Continue reading

Turkmenistan, Finland agree to avoid double taxation

Majlis (Parliament) of Turkmenistan has ratified an agreement with the government of Finland for the avoidance of double taxation with respect to taxes on income during the regular meeting, the Turkmen government said Jan.13. Turkmenistan believes that namely innovations ensured Finland’s competitiveness at international level. The message of the State… – Continue reading

Luxembourg – Croatian DTA to enter into force on January 13, 2016

On January 11, 2016 the Luxembourg tax authorities issued a newsletter announcing that on January 13, 2016 the Agreement between the Grand Duchy of Luxembourg and the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on… – Continue reading

Tax Inversions Hinder Economy, Boost Large Caps

Tax inversions and corporate tax rate cuts would be huge for these stocks Certain politicians are decrying a tax move known as an “inversions,” which allow a U.S. company to merge with a foreign one with a more favorable tax rate. Yet, it’s the politicians who created the necessity for… – Continue reading

Canada: Tax-dispute arbitration procedures, under income tax treaty with UK

Canada and the United Kingdom have signed an agreement that clearly outlines procedures for the application of the arbitration provisions of the Canada-United Kingdom income tax treaty. The agreement provides for a clearly outlined process for the arbitration of tax disputes between the two nations. The agreement establishes rules and… – Continue reading

India: Swiss Apex Court Denies Treaty Benefits For Dividend On Securities Acquired For Hedging Derivative Contracts

Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading

UK Tax Treaties With Croatia, Bulgaria In Force

The UK tax authority, HM Revenue and Customs (HMRC), has announced that new double tax avoidance treaties with Bulgaria and Croatia have entered into force. The 2015 UK-Bulgaria double tax agreement was signed on March 26, 2015, and replaces the former 1987 treaty. It generally limits the withholding tax rate… – Continue reading

Belgium’s $763 million tax loophole shut in EU payback order

AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading