Category: Royalties

Your Taxes: Israel to sign tax treaty with Panama

With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading

Your Taxes: Going International

Going offshore means registering any intellectual property (IP) in an offshore company and delegating R&D and marketing to onshore companies. Money doesn’t grow on trees, and taking your business international is no picnic. On June 12, the International Business Structuring Association (IBSA) held a seminar to discuss ways of growing… – Continue reading

Administration of withholding tax (2)

The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading

Cyprus: New Cyprus-UAE Double Tax Agreement Takes Effect

New agreement The new double tax agreement between Cyprus and the United Arab Emirates took effect from January 1 2014. For the most part, the agreement reproduces the corresponding provisions of the latest Organisation for Economic Cooperation and Development (OECD) Model Tax Convention verbatim. The principal departures from the OECD… – Continue reading

Nokia India, Finnish parent discuss tax evasion in emails

The department had slapped a tax demand of Rs 2,080 crore on the company last year while re-opening the assessment for AY 2006-07 and 2007-08. As Finnish phone-maker Nokia strives to meet the April 30 deadline for sealing the $7.2 billion deal with Microsoft, its tussle with the Indian tax… – Continue reading

Corporate Tax: OECD’s Saint-Amans says “Double Irish Dutch” sandwich tax scheme will be axed

Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading

Multinationals face new rules on aggressive tax avoidance

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

Switzerland Revives DTA With Argentina

Switzerland and Argentina have recently signed a new agreement for the avoidance of double taxation with respect to taxes on income and on capital. The treaty replaces the provisional agreement of 1997 and provides for the exchange of information upon request, in line with the current international standard. This is… – Continue reading

Developing countries ‘lose taxes to profit shifting’

STUDIES show multinationals shift profits of $365bn a year from developing to developed countries through transfer pricing mechanisms, the South African Revenue Service (SARS) said on Tuesday. Over three years South Africa has seen “hundreds of billions of rand” leaving in royalties, management and service fees and intellectual property payments,… – Continue reading

How to Get Your Profits Out of China

BEIJING – Wholly Foreign Owned Enterprises (WFOEs) are able to repatriate funds out of China in a variety of forms, for which tax implications vary according to the form of repatriation used and the Double Taxation Agreement (DTA) in place between China and the recipient country. The four most commonly… – 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