Category: Withholding Tax

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...

Push to draw up Cambodia-Thai tax treaty

Representatives from the tax authorities of Cambodia and Thailand have agreed in principle to speed up a proposed double taxation agreement that would protect their nationals from dual taxation and encourage bilateral investment. The agreement was made last week during a two-day consultation workshop in Bangkok for tax officials from...

Draft modifications to tax provisions applicable to foreign companies with poem in India

Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of...

Memo to: real estate vendors – if the sale price is $750,000 or more you need a Tax Clearance Certificate for settlement

In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more...

Malta Pushes to Ease EU Cross-Border Interest, Withholding Tax

European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial...

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...

Ukraine Ratifies Tax Treaty With Malta

On April 13, 2017, the Ukrainian Parliament ratified its tax treaty with Malta, which provides for lower withholding tax rates on dividends, interest, and royalties. Under the deal, the withholding tax rate for dividends would be capped at 15 percent. A special rate of five percent would apply to dividends...

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons...