For the third year on the trot, Shell service stations generated billions of dollars and revenue but not a cent in company tax. In fact the owners of the sunny yellow servos reported tax benefits in all three years despite total sales which may be in excess of $60 billion…. – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
Tax Commissioner Pierre Moscovici has said that European Commission law was not breached in the case of a French professional association taxing royalty payments earned by UK musicians in France. In a written question to the European Commission, Julie Girling, a UK Member of the European Parliament (MEP), alleged that… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
Democratic presidential candidate Hillary Clinton and her husband former President Bill Clinton made almost $28 million last year and paid about $10 million or 36% of that in federal taxes, according to tax returns her campaign released Friday. The Clinton campaign made public eight years of returns — covering 2007… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
FEW tax hikes have been timed so badly – and retracted so fast – as that imposed on mineral royalties by Zambia’s President Edward Lungu in January. After threats of divestment from major mining houses and an outcry from the country’s Chamber of Mines, the massive hike in royalty taxes… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
Law 20,780 – published in the Official Gazette on September 29 2014 – introduced the most complex and comprehensive tax reform in Chile for decades. Several provisions are already in force, while others will enter into force on January 1 2016. Most of the remaining provisions will be in full… – Continue reading
Mexico on July 17, 2015, published the text of its agreement with Turkey to avoid double taxation between the two countries and prevent tax evasion. The double tax agreement (DTA) was signed in 2013 and is valid from July 23, 2015. Under the agreement, dividends will be subject to a… – Continue reading
The European Parliament’s special tax committee is seeking to punish multinationals for refusing to send representatives to a hearing in June by revoking lobbyist passes and preventing access to senior European Commission officials. AB InBev, AmazonEU, Barclays Group, Fiat Chrysler Automobiles, Google, HSBC Bank, Ikea, McDonalds and The Coca-Cola Company… – Continue reading
July 17: The Japanese Ministry of Finance on 16 July 2015 announced that the governments of Japan and Germany reached an “agreement in principle” for a new income tax treaty. The new treaty would replace the existing agreement signed in 1966, and subsequently amended in 1979 and in 1983. According… – Continue reading
Energy giants called to explain billions in tax havens To describe Gorgon as another super-sized resources project in Western Australia does not do justice to the scale and scope of the venture. When the taps are turned on later this year and liquefied natural gas begins to flow, Australia will… – Continue reading
Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading
On 10 July 2015, Liechtenstein and Switzerland signed a new Income and Capital Tax Treaty. Once in force and effective, the new treaty will replace the old one of 1995. The new treaty will come into force after the two countries exchange ratification instruments. The provisions of the new treaty… – Continue reading
One of the most immediate and obvious consequences of globalisation is the impact of domestic tax policies in other countries on the economy of Tanzania. This has necessitated the continuous evaluation of the tax regime in Tanzania and brought about crucial fiscal and economic reforms in the country. Hence, the… – Continue reading
Tax avoidance tactics of multinational companies have angered Australians, but an Australian mining firm used such methods in Malawi. Tax avoidance tactics of multinational companies have angered the public and placed pressure on the Abbott government to prevent profits being exported offshore. But an Australian uranium miner is defending the… – Continue reading
On 17 June 2015, the Income Tax Treaty between Malta and Moldova entered into force and will come into effect on 1 January 2016. The Treaty was signed on 10 April 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: where the dividends are paid by… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading
Calcutta, July 5: Singapore and Hong Kong, with their low corporate tax rates, have started to hove into view on the radars of multinational companies that are looking to lower their tax burdens through profit shifting. Profit shifting is a perfectly legal way of moving the earnings of an MNC… – Continue reading
New Zealand-Canada double tax agreement to help investors WELLINGTON, July 2 (Xinhua) — A new double tax agreement between New Zealand and Canada is set to facilitate investment and trade between the two nations, Revenue Minister Todd McClay said Thursday. The new agreement will lower withholding taxes on dividends, interest… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
The South African Revenue Service (SARS) has extended its Third Party Business Requirement Specification (BRS) for data submissions via Direct Data Flow (DDF) to include withholding tax on interest and tax-free savings and investments. The extension will be available for year-end data submissions due on May 31, 2016 (for the… – Continue reading
The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading
THERE have been a number of challenges in implementing the 2015 mining tax regime, says Zambia Revenue Authority commissioner general Berlin Msiska. And Msiska says there is an immoral aspect to tax avoidance, even if it might be said not to be illegal. Msiska said in an interview that tax… – Continue reading
The G20’s efforts to crack down on multinational tax avoidance are likely to be defeated by national self-interest, particularly from the United States, one of Australasia’s top tax advisers says, reports the Sydney Morning Herald. Rod Houng-Lee, formerly Asia Pacific Tax Leader head of tax in Asia Pacific for big-four… – Continue reading
Pretoria — Government has gazetted the South Africa-Mauritius tax treaty which came into force at the end of May, said National Treasury. “This new treaty reflects changes in the tax policies of the two countries and is in line with international best practices to deal with tax abuse as outlined… – Continue reading
With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading
MUSCAT: Japan-Oman robust economic relationship is set to leap to a new level with the signing of an investment agreement between the two countries, which is expected in the second quarter of this year, says Japan’s ambassador to the Sultanate. “The signing of the Japan-Oman Investment Agreement is expected to… – Continue reading
Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading
TRENTON – A New Jersey think tank says the state could reap hundreds of millions of dollars by changing tax rules to close loopholes and make multi-state corporations pay what they owe. The left-leaning New Jersey Policy Perspective called on lawmakers to enact combined reporting to thwart businesses that operate… – Continue reading
Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading
The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading
From today, negotiation on the Investment Promotion and Protection Agreement (IPPA) between Nigeria and Singapore will start in Abuja, aimed at enhancing business between the two countries. Revealing this in an interview with the African Independent Television (AIT), Nigerian High Commissioner to Singapore. Mrs. Nonye Rajis-Opara, said there would be… – Continue reading
Dutch tax advisors are increasingly questioning the way some companies use shell or letterbox companies purely to move income from interest and royalties through the Netherlands to tax havens, the Financieele Dagblad says on Friday. A committee from the European parliament is in the Netherlands on Friday to look into… – Continue reading
Bangladesh Bank will take all possible measures to liberalise country’s foreign-exchange rules and regulations for attracting foreign investors to a number of proposed economic zones. The decision was taken at a meeting between the central bank and the Bangladesh Economic Zones Authority (BEZA) at the BB headquarters Tuesday. Presided over… – Continue reading
Fortescue Metals Group established a company in Singapore that could buy and sell its iron ore more than a year before it started attacking its rivals for doing the same thing. The company, called Fortescue International Marketing, is incorporated and domiciled in Singapore. Still dormant, it is ready to be… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
The first fiscal amendment of the Juan Carlos Varela government was passed earlier this month on May 4, by Law 27 of 2015. Here are two important pointers of the fiscal reform: 1. TAXABLE INCOME PRODUCED IN PANAMA Article 694 of the CF originally included as taxable income the income… – Continue reading
France and Germany want to see common basic corporation tax rates across the EU, according to reports France and Germany are pushing plans to introduce a minimum corporation tax rate across the continent, it was reported today, in a move that could result in higher taxes on British companies. European… – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
May 25 (Reuters) – Romania’s government will send a draft law on royalty taxes for the oil and gas sector to parliament in September, Deputy Finance Minister Dan Manolescu told an energy seminar on Monday. The new tax system will likely include differentiated royalties for onshore and offshore extraction and… – Continue reading
On 22 May 2015, Switzerland and Oman signed an Income Tax Treaty. 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 calendar year next following that in which the agreement enters into force…. – Continue reading
Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading
Tax Treaty Details Become Available The details of the Income Tax Treaty between Mauritius and the Republic of Congo have become available. 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 calendar year… – Continue reading
Details of new Tax treaty Become Available The details of the new Income Tax Treaty between Netherlands and Germany have become available following its ratification by Netherlands on 15 May 2015. The new treaty was signed on 12 April 2012. Once in force and effective, the new treaty will replace… – Continue reading
