Category: Withholding Tax

China’s IIT Reform: Seven Key Points from the Draft Implementation Rules

Many taxpayers in China have had questions about how the government would change the individual income tax (IIT) law since the amendment was passed earlier this year. Recently, however, the tax authorities released a draft of the amendment’s implementation rules and measures for comment. While the draft implementation rules and...

PenSam to step up scrutiny of partners as €55bn tax scandal unfolds

The head of one of Denmark’s biggest pension funds has spoken out to condemn a wide-scale tax fraud uncovered by a media investigation. Danish national broadcaster DR, newspaper Politiken and other European media outlets in the last three months have published articles detailing a withholding tax scam – dubbed ‘Cum-Ex’...

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information...

Nigeria-Singapore income tax treaty to take effect Jan. 1

A bilateral double taxation agreement between Nigeria and Singapore generally is to take effect Jan. 1, 2019, although in Singapore, provisions regarding income taxes other than withholding taxes are to take effect Jan. 1, 2020. The treaty, also known as a DTA, is to affect how each country’s income tax...

UK withholding tax on interest paid to non-residents

The UK does still have one significant disadvantage namely the 20% withholding tax imposed by UK domestic law on “yearly interest” that arises in the UK is paid to persons whose “usual place of abode” is outside the UK. The UK is normally regarded as an attractive location for the...

IRS spent $380M on FATCA, but still can’t enforce it

The Internal Revenue Service spent nearly $380 million to implement the Foreign Account Tax Compliance Act, but so far isn’t prepared to enforce the law, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined the IRS’s efforts to implement FATCA, which was included...

Tax Competitiveness in India: Changing Rules, Trends in Taxation

Ease of doing business and tax reforms are at the center of India’s growth agenda as the country pitches itself as the leading investment destination among global emerging markets. Yet, India’s tax competitiveness record remains mixed. At a time when the U.S., U.K., and Japan have slashed their corporate tax...

Withholding Corporate Income Tax in China

In China, withholding Corporate Income Tax (CIT) is applied to the following China-sourced incomes derived by non-resident enterprises without establishments in China, or to that derived by non-resident enterprises with establishments in China but whose income is not related to these establishments: Dividends, bonuses, and other equity investment proceeds; Interests,...

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying...

Taxation agreement with Singapore in effect

The double tax avoidance agreement (DTA) between Cambodia and Singapore came into effect this month, helping clarify taxation rights on all forms of income arising from cross-border business activities, while minimising double taxation. On January 1 the Inland Revenue Authority of Singapore (IRAS) issued an announcement stating that the DTA...

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended...

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice...

Serbia to Abolish Full Blown Withholding Tax on Non-Resident Service-Providers and Simplify Conditions for Tax Deductibility of NPL Write-Offs for Serbian Banks

The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition...

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the...

Dutch government continues with dividend withholding tax proposal and announces conditional retroactive amendment to CIT fiscal unity regime

In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal...

Aircraft Leasing in Russia – Key developments in Russian tax and insurance laws

Summary: With effect from 1 January 2017, a number of amendments to Russian law have come into force which will affect aircraft leasing arrangements for lessors and financiers that have aircraft leased or financed with Russian operators. These amendments have started to affect negotiations and re-negotiations of leases with Russian...

Grenada Gears Up For FATCA

Grenada’s Inland Revenue Division has completed a series of training exercises for its staff and the island’s financial institutions in preparation for the start of reporting under the US Financial Account Tax Compliance Act. Reporting by FIs under FATCA is governed by a November 2016 inter-governmental agreement between the US...

Court orders developer to reveal condo-flipper info

A Federal Court judge has approved at least one court order that will require a British Columbia developer to turn over information to tax officials about people who bought and flipped condo units before or during construction. And several similar applications are under way, reflecting the federal government’s efforts to...

Briefing: Proper plan design is way forward

International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another...

Switzerland Consulting On WHT Reforms

The Swiss Federal Department of Finance is consulting on proposals to amend the Withholding Tax (WHT) Ordinance, to more clearly define the rules for non-resident taxpayers. Under the proposed reforms, “quasi-residents” will be permitted to request a subsequent ordinary tax assessment. “Quasi-residents” are employees who are not domiciled in Switzerland...

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If...

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...