The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian “excess profit” tax rulings granted to multinationals between 2005 and 2014 provided benefits that are contrary to EU State aid rules. ... - Continue reading
You may evaluate claiming foreign tax credits under the India-US Double Tax Avoidance Agreement, for the taxes, if any, paid in the US on the salary received during the assignment, subject to satisfaction of conditions ... - Continue reading
Colombia's National Directorate of Taxes and Customs (DIAN) released detailed guidelines (the Guidelines) to clarify the procedure for Advanced Transfer Pricing Agreements (APAs) requests in order to ensure certainty between the parties regarding their transfer pricing arrangements. ... - Continue reading
Services sector professionals in Cyprus are monitoring Kazakhstan’s emerging market economy for some time now and they have set an ambitious goal. This is no other than turning the Mediterranean island into the bridge between the booming Central Asia country and Europe. This is what Costas Markides of KPMG Cyprus… – Continue reading
The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – Continue reading
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals. Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading
A Tax Treaty (TT), in general terms, is an agreement between two or more jurisdictions that regulates the tax amount that an individual or a company must pay, so they are not taxed twice on the same type of income. ... - Continue reading
Georgia, an Eastern European Country, was ranked 6th in the World Bank Group’s 2019 “Doing Business” survey. ... - Continue reading
Canada and Switzerland have deposited their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the OECD today announced. ... - Continue reading
One of the key objectives of the Income Tax (Transfer Pricing) Regulations, 2018 (NTPR) as captured in regulation 2(e) is to provide taxable persons with certainty of transfer pricing treatment in Nigeria. ... - Continue reading
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading
ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading
ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading
The European Union has added further impetus to its objective of providing greater transparency with regard to harmful tax practices through an amendment to EU Directive 2011/16/EU. ... - Continue reading
On July 16, 2019, the US Senate ratified a new protocol that amends the 2013 Double Taxation Treaty signed between the US and Spain. ... - Continue reading
This is the first in a series of of Mauritius Regulatory Alerts in which we bring you an overview of the latest legal and regulatory developments in the offshore world, with a particular focus on Mauritius. ... - Continue reading
Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading
The Republic of Vanuatu is a group of islands in the Pacific. The country exists by growing fruits, fishing, and tourism. In 2016, the government introduced the program of achieving local citizenship through investment to increase the flow of external finance. Foreign businessmen want to get a second passport in… – Continue reading
Tax residence is one of the most important factors when ascertaining an expatriate worker's tax obligations. ... - Continue reading
By virtue of the powers vested under, Section 90 of the Income Tax Act, 1961("the Act"), India has entered into the Double Taxation Avoidance Agreement on 18th July, 1994 with China signed at New Delhi. ... - Continue reading
The Australian government on August 9 published the synthesized texts of Australia’s bilateral tax treaties with France, Finland, and Malta as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
Armenia and Kyrgyzstan have signed a double tax treaty during the Eurasian Inter-governmental Council session in Cholpan-Ata, Issyk-Kul. ... - Continue reading
WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading
NICOSIA, Aug. 7 (Xinhua) — Cypriot Finance Minister Harris Georgiades’ proposal of a major reform of corporate taxation has triggered strong objections from entrepreneurs, who fear that it would lead to an increase of their total tax burden. Georgiades said on Wednesday that his proposal, which included taxation on offshore… – Continue reading
Ukraine today deposited with the OECD legal documents ratifying a multilateral tax treaty called the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as a result of the two countries’ ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into effect on August 1. ... - Continue reading
While considering moving a business into a new market, one of the key consideration is that country's tax regime. What are the incentives that would attract foreign investment? Are there any double tax treaties in place? What is the rate for corporate tax? ... - Continue reading
The proposal intends to tax gift of money exceeding ₹50,000 made by residents to non-residents that were earlier claimed to be outside the ambit of India taxation ... - Continue reading
Proposals made by Nirmala Sitharaman at G20 Summit could alter the stasis between large corporations and tax havens. ... - Continue reading
The OECD today announced that Norway has deposited its instrument ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
Article 7 – Prevention of Treaty Abuse – of the Multilateral Instrument (the MLI) contains three opt-in provisions. ... - Continue reading
NAIROBI, July 23 (Xinhua) — Kenya and Botswana on Tuesday signed three key agreements to help deepen bilateral ties between the two African countries. The agreements, which cover bilateral trade, air transport and ICT, were signed at the end of talks held between visiting Botswana president Mokgweetsi Masisi and his… – Continue reading
The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading
Intangibles are key sources of differentiation for businesses and typically, they help drive revenue, manage cost or both. As a result, many businesses make significant investments in developing, enhancing, maintaining and protecting unique and valuable intangibles to help drive their businesses. ... - Continue reading
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
The Japanese government on July 1 published the synthesized text of the Japan-United Arab Emirates 2013 tax treaty, taking into account changes made by the bilateral tax treaty on account of both countries’ later ratification of the the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
An amending protocol to the China-India tax treaty entered into force from June 5, the Indian government announced on July 17. ... - Continue reading
G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. ... - Continue reading
The OECD on July 5 requested taxpayer feedback on the tax treaty dispute resolution process in Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco,and Tunisia. ... - Continue reading
The United States Senate could soon approve ratification of four long-pending double tax avoidance treaty protocols. ... - Continue reading
On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement (IGA) with the United States to implement the requirements of the US Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
NAIROBI, July 14 (Xinhua) — Kenya and Turkey are set to sign a double taxation avoidance agreement by the end of 2019, a Turkish diplomat said on Sunday. Ahmet Cemil Miroglu, Turkish ambassador to Kenya told journalists in Nairobi that both countries are keen to improve the environment for investment… – Continue reading
The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading
State-run Philippine Amusement and Gaming Corp. expressed optimism the government will not impose higher taxes on offshore gaming operators in the country to encourage them to stay here. Pagcor chairman and chief executive Andrea Domingo said at the sidelines of the opening of the first Philippine-Asian Gaming Expo held on… – Continue reading
The following is Part 2 of the Application of the MAP Article in the MLI to the Covered Tax Agreements that specifically deals with How contracting jurisdictions apply Article 16 to their CTA's. ... - Continue reading
Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent. ... - Continue reading
On April 25, 2019, the OECD released the 2017 full version of the Model Tax Convention on Income and on Capital ("MTC"). ... - Continue reading
