In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading
The 3 Tax Packages are as follows: 1) Tax package to boost earned income Law: Businesses that increase employee wages will receive a 10 percent tax credit (5% for large corporations) on the portion that was increased, on the condition that wage growth exceeds average growth for the past 3… – Continue reading
Barbados and Slovakia signed a double tax agreement on October 28, 2015, to boost investment and trade prospects. The DTA allocates taxing rights to the two territories, to ensure that cross-border income is not taxed twice. It further stipulates that cross-border income from dividends will be subject to a withholding… – Continue reading
The Income Tax Treaty between Hong Kong and South Africa entered into force on 3 November 2015. The provisions of the Treaty will become effective on 1 April 2016 in Hong Kong and on 1 January 2016 in South Africa. The Treaty was signed in October 2014. In accordance with… – Continue reading
TThe Income and Capital Tax Treaty between Cyprus and Switzerland entered into force on 15 October 2015. The provisions of the treaty will become effective on 1 January 2016. The treaty was signed on 25 July 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0%… – Continue reading
Non-resident Indians (NRIs) have one more investment option to choose from. The Reserve Bank of India (RBI) has allowed NRIs to invest in the National Pension System (NPS), under Foreign Exchange Management Act. NPS will allow NRIs to invest in a mix of equities and debt and save for their… – Continue reading
The Swiss Federal Council has adopted dispatches on a new double tax agreement (DTA) with Liechtenstein and a protocol to the agreement with Norway. The DTA with Liechtenstein was signed on July 10, 2015. It replaces the existing 1995 treaty. The agreement provides that old age and survivors’ insurance (AHV)… – Continue reading
At the end of this year an amnesty for UK tax resident persons whose offshore income and gains have not been disclosed to HMRC closes, and it is important the implications are understood according to Michael Crowe, a director at Grant Thornton in the Isle of Man. In the UK’s… – Continue reading
The most common error NRIs commit while filing tax returns is to use the status of residents in India. Non-resident Indians (NRIs) in the UAE enjoy the twin advantages of not having to pay tax in their country of domicile and most sources of income are exempted from tax in… – Continue reading
South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading
Possible opportunities for refund of Dutch dividend withholding tax On 17 September 2015, the Court of Justice of the European Union (“CJEU”) ruled in three distinct (yet comparable) cases that the levy of Dutch dividend withholding tax in relation to portfolio shareholdings in Dutch companies is in conflict with the… – Continue reading
The European Union (EU) is pushing ahead with its most ambitious plans to date to eliminate tax competition between member states and roll out a single market for products and services. While the commission focuses on levelling prices for products and services across the 28 member state bloc, a European… – Continue reading
How analytics will nab cheaters. Tomorrow is the Australian Taxation Office’s official cutoff for 2014-15 personal tax returns. Will you be tempted to tell fibs about your income? How will the tax man ever know? Take note: it may already know – or at least can find out – a… – Continue reading
Bern, 10.29.2015 – The double taxation agreement (DTA) in the area of taxes on income and on capital between Switzerland and Argentina is on 27 November 2015 to enter into force after the ratification procedures in Switzerland has been completed. It will replace the agreement of 1997 and corresponds to… – Continue reading
Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading
An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading
MPs have proposed that the basic rate of profit tax should be reduced to 15% from the current of 18%, and taxation of distributed profit and payments equaled to it should be introduced, according to a draft bill on tax reform registered in the parliament by 114 lawmakers on Monday…. – Continue reading
JAKARTA, Oct 28 (Reuters) – Indonesian conglomerate Lippo Group plans to shift two real estate investment trusts (REITs) with 35 trillion rupiah ($2.6 billion) in assets from Singapore to Indonesia next year in order to benefit from new tax breaks offered by Jakarta. Lippo’s move could be followed by at… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
BRUSSELS, Oct 27 (KUNA) — The European Parliament adopted a resolution Tuesday by 593 votes to 37 on a deal with Switzerland to make it harder for EU citizens to hide cash from the taxman in Swiss bank accounts. Under the deal, the EU and Switzerland will automatically exchange information… – Continue reading
Parliament adopted its stance on a deal with Switzerland to make it harder for EU citizens to hide cash from the tax man in Swiss bank accounts, in a vote on Tuesday. Under the deal, the EU and Switzerland will automatically exchange information on the bank accounts of each other’s… – Continue reading
Profit-shifting has not paid off for petroleum multinational Chevron, slugged with a tax bill for $322 million thanks to a Supreme Court decision on Friday. Chevron has been under close scrutiny this year, particularly since a senate inquiry into tax-avoidance in April which also put mining giants BHP, Rio Tinto,… – Continue reading
Taiwan and Mainland China signed the “Cross-straits Agreements for the Avoidance of Double Taxation on Income and Solidifying Cooperation with respect to Taxes” (hereinafter referred to as “Cross-straits ITA”) on 25 August 2015. After the draft Article 25-2 of the “Act Governing Relations between the People of the Taiwan Area… – Continue reading
While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading
Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
Cyprus will as of January 1, 2016 have a new tool in its arsenal to identify monies hidden abroad as the island will begin implementing the Common Reporting Standard (CRS), the Institute of Certified Public Accountants said. The CRS is formally referred to as the Standard for Automatic Exchange of… – Continue reading
A new Protocol to the income tax treaty between Indonesia and the Netherlands was signed 30 July 2015 and will be effective 31 days after formal approval and ratification by both governments. Among the measures contained in the Protocol are revisions to the withholding tax rates on dividend payments. The… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
Extensive use has been made of trusts in South Africa, both for tax planning and for the purposes of reducing (or eradicating) one’s estate duty liability upon death. As the use of offshore trusts as a estate and wealth planning vehicle increases, one needs to consider if and how offshore… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
Bern, 14.10.2015 – Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Oman and submitted it to Parliament for approval. The agreement will promote bilateral economic relations and contains provisions on the exchange of information upon request in accordance with the OECD standard. Aside… – Continue reading
Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits offshore, a sufficient presence ”on the ground” can pull sales income (and… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
Emmanuel Mayah, Jeff Mbanga, Francis Kokutse and Nick Mathiason contributed to this joint investigation by the M&G Centre for Investigative Journalism (amaBhungane) and Finance Uncovered, a global reporting project involving journalists in 54 countries. Shortly after Cyril Ramaphosa left MTN to become South Africa’s deputy president last year, he lashed… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
MTN Uganda has been accused of failing to provide evidence to justify shifting huge amounts of cash out of Uganda to a briefcase company located in Mauritius, potentially lowering its tax bill in Uganda – the subject of which remains an ongoing dispute with Uganda Revenue Authority, it has emerged…. – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
The Council of Ministers has approved an agreement between the Republic of Turkey and Republic of Kosovo (“State” or collectively “States”) to prevent tax evasion and double income taxation for residents of the two countries (“Agreement”). On 19 August 2015, the Council of Ministers approved the Agreement and its annexed… – Continue reading
What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading
The OECD’s final package of proposals for reforming the international system for taxing companies brings to an end the two-year BEPS project led by the OECD and other G20 countries which also included participation by representatives of developing countries, business, academia and NGOs. Developing the BEPS, or Base Erosion and… – Continue reading
By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading
The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on… – Continue reading
European Commission list identifies the city as one of 30 non-cooperative tax jurisdictions, reports the South China Morning Post. The European Commission is likely to remove Hong Kong from its list of top 30 tax havens, according to a source familiar with the situation. The source, who cannot be identified,… – Continue reading
The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to legal persons tax and that qualify as founders or third-party beneficiaries of so-called… – Continue reading
On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the… – Continue reading
In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading
