Category: Tax treaties

The Luxembourg double tax treaties network — 12 March update

12 March 2014: In its 2013 Annual Report, the Luxembourg Direct Tax Authorities reported that they have negotiated new tax treaties with Hungary, New Zealand, the UK and Uruguay. It is also reported that 659 exchanges of information upon request, spontaneous information exchanges and automatic exchanges of information have been… – Continue reading

Use HK’s access to marts in China, Japan and S Korea

KUALA LUMPUR: Small and medium enterprises (SMEs) should tap Hong Kong’s access to the markets in China, Japan and South Korea to gain tax advantages under the double-taxation deduction pact signed between Malaysia and HK. Hong Kong Trade Development Council deputy executive director, Margaret Fong, said HK SMEs paid five… – Continue reading

Legislation enabling FATCA overrides Privacy Act

The Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill contains proposed legislative amendments to give effect to the intergovernmental agreement (IGA) New Zealand is currently negotiating with the United States in respect of the United States’s Foreign Account Tax Compliance Act (FATCA). The Commentary to the Bill states that… – Continue reading

United Kingdom: The OECD Base Erosion And Profit Shifting Action Plan

There has been considerable publicity in recent months on the alleged tax avoidance perpetrated by multinationals that has resulted in the Organisation of Economic Cooperation and Development (OECD) publishing its action plan on base erosion and profit shifting (BEPS). The action plan, consisting of 15 proposals to counter the perceived… – Continue reading

Cyprus: Cyprus Signs Five New Double Tax Treaties

As of January 1st 2014, Cyprus entered into five new Double Tax Treaties (DTT’s) with Estonia, Finland, Portugal, Spain and Ukraine expanding its already rich list of DTTs. All the agreements aim to avoid double taxation between the mentioned countries and follow the OECD conventional model on income and capital. The… – Continue reading

Canada: Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a business operates, in a bid to enhance revenue authorities’ abilities to identify high risk transfer pricing situations and to make… – Continue reading

Black money: Swiss exchanging ‘lawful’ info with India

New Delhi: With India stepping up its pursuit of alleged black money in Swiss banks, Switzerland says it is exchanging information with Indian authorities on all lawful requests, but cannot help on enquiries based on stolen banking data. The European country, which has often been accused of being the most… – Continue reading

Aligning tax with the times

The aggressive approach of Indian tax authorities on transfer pricing and international tax matters underlines the government’s intention of taking strong action to defend its tax base. When it comes to taxation of cross-border transactions, India’s inclination to widen the source-based tax rules is clearly demonstrated by the retrospective amendments,… – Continue reading

New Discussion Launched on Tax Treaty Abuse

PARIS – The OECD is initiating an international discussion into measures to prevent the occurrence of profits shifting and tax evasion through the abuse and misuse of international tax treaties. Late last week the Organization for Economic Cooperation and Development released a public discussion draft “Preventing the Granting Of Treaty Benefits In… – Continue reading

Indo-Netherlands BIPA pact doesn’t cover taxation: FinMin

New Delhi: The Income Tax department has rebutted Vodafone’s notice under BIPA saying that the pact between India and Netherlands does not cover taxation issues. “Tax department has sent its response to Vodafone saying BIPA does not cover tax issues,” an official source said. The response to the Bilateral Investment… – Continue reading

Switzerland Refuses To Share Information With India On Black Money

BANGALORE: In response to the letter written by finance minister P. Chidambaram, the Swiss finance minister Eveline Widmer-Schlumpf has informed that the Swiss authorities can’t share the details of the bank accounts held by Indians in Swiss bank without the consent of the account holders, reports Economic Times. An Indian… – Continue reading

Black money: Switzerland refuses to share information on bank account holders, Delhi mulls strong response

NEW DELHI: The Swiss authorities have told the Indian government they will not be able to share information on bank accounts without the consent of the account-holders. In a letter last month, Switzerland’s finance minister also told her Indian counterpart that the 2011 Double Taxation Avoidance Agreement, under which India… – Continue reading

Luxembourg: on-shore financial center with a commitment to privacy

Luxembourg has been widely hailed as an international investment center for years. The Association of the Luxembourg Fund Industry (ALFI) provides a number of reasons underlying the country’s designation as a top fund-industry choice. Its legal and regulatory framework for investment funds is recognized for its excellence by the global… – Continue reading

Russia targets offshore investors

The Russian Finance Ministry will offer companies based offshore but with operations in Russia a choice: either disclose their ultimate beneficiaries and maintain their zero tax rate, or pay taxes at the higher Russian rate. Under Russia’s current corporate tax structure, offshore beneficiaries of Russian companies are treated as de-facto… – Continue reading

Govt prepares strategies for withdrawing funds kept in Singapore

Batam, Riau Islands (ANTARA News) – Indonesias finance ministry is preparing four strategies to withdraw funds worth Rp1,500 trillion kept in Singaporean banks, an official stated here on Wednesday. “We are preparing four strategies,” remarked Deputy Minister of Finance Bambang Brodjonegoro. The four strategies are tax incentives, eradication of double… – Continue reading

‘Drop in new India-focused funds in Mauritius’

The Vodafone tax issue has affected investor sentiments towards India: ABAX Corporate CEO NEW DELHI, FEBRUARY 26: The Vodafone tax dispute and General Anti-Avoidance Rules have impacted investor sentiment badly. Coupled with the delay in revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius, fund flow from the island-nation has… – Continue reading

Cyprus: Signing Of Agreement For The Avoidance Of Double Taxation Between Cyprus And Norway

The Cyprus government has announced the signature of a new double taxation agreement with Norway. Double taxation avoidance between Cyprus and Norway is currently regulated by the 1951 double tax agreement between Norway and the United Kingdom, which was extended in 1955 to include several British colonies, including Cyprus. On… – Continue reading

Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers

The overlap of Australia’s new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers – particularly for the arm’s length amount-of-debt test. Australia legislated comprehensive new transfer pricing laws in 2012[i] and 2013.[ii]  These laws were passed in two installments: Subdivision 815-A, dealing with… – Continue reading

Double taxation agreement with Norway

CYPRUS and Norway on Monday signed an agreement for the avoidance of double taxation. A statement said the text agreed between the finance ministries of the two countries would contribute to the further development of trade and economic relations between Cyprus and Norway, as well as other countries. “The updating,… – Continue reading

Barbados To Expand Double Taxation Network

Barbados’ financial-services sector is rated as the second-largest source of foreign exchange earnings, behind tourism, for which new markets are being sought outside of Canada. On Thursday, central bank governor, Dr DeLisle Worrell, said the country has been losing business in its International Business and Financial Services Sector (IBFS), which… – Continue reading

Switzerland to back OECD tax treaty

It’s a u-turn, but unavoidable: bankers and politicians are preparing for the automatic exchange of tax information. Switzerland has helped develop the new standard, which the OECD wants to fast-track worldwide. The days when Swiss finance ministers said banking secrecy was non-negotiable and carved in stone are over. Switzerland has… – Continue reading

Dual taxation treaty modalities to be finalised: Pak-Afghan JEC meets on February 23

Pakistan and Afghanistan would finalise modalities for signing Avoidance of Double Taxation and the Prevention of Fiscal Evasion Convention in the next meeting of the 9th session of the Pak-Afghan Joint Economic Commission (JEC) to be held on February 23-24 in Kabul. A senior FBR official told Business Recorder here on Tuesday… – Continue reading

India, Switzerland agree on liberal terms for tax information exchange

NEW DELHI: Continuing its crackdown on black moneymenace, India has entered into an agreement with Switzerland for liberal interpretation of identity requirements for gathering information about illicit funds stashed away by its citizens in Swiss banks. “Government has also signed a mutual agreement with government of Swiss Confederation for liberal interpretation of the… – Continue reading

Margelov: agreement on avoiding double taxation is in Russia’s interests too

Russian Federation Council foreign committee chairman Mihhail Margelov said at his meeting with Estonian Riigikogu speaker Ene Ergma on Thursday that the agreement on avoiding double taxation between the two states is in Russia interests too, LETA/Public Broadcasting reports. Ergma expressed concerns over the halting of the ratification process of… – Continue reading

Ambassador Berhane meets the Parliamentary Secretary of Foreign Ministry of Canada

State Minister Ambassador Berhane met on Monday (January 27) with Mr. Deepak Obhrai, Parliamentary Secretary of the Foreign Ministry of Canada. Their discussions focused on strengthening the bilateral relations between Ethiopia and Canada. Mr. Obhrai said he appreciated the growing relationship between the two countries and was looking for additional… – Continue reading