Category: Double Tax Treaty

Luxembourg Says EU’s Digital Tax Must Be Lawful

Luxembourg Finance Minister Pierre Gramegna has said that any special tax measures against large digital companies should respect European Union law. Gramegna made the comments during an official visit to Paris earlier this month where he held a series of working meetings with French government counterparts. “Pierre Gramegna stressed that… – Continue reading

India-Iran DTAA – A Step Forward in India’s Economic Engagement with Central Asia

India and Iran signed a Double Taxation Avoidance Agreement (DTAA) in February, during Iranian President Hassan Rouhani’s official visit to India. The ‘Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income’ aims to encourage the movement of investments and services… – Continue reading

High net worth expats in UAE increasingly applying for second passport

High net worth residents in the UAE are increasingly applying for second passports to avail of maximum visa-free travel opportunities, expand businesses and avoid double taxation, experts have said. According to companies involved in citizenship programmes, most of the demand for second citizenship programmes is coming from Indians, Pakistanis, Syrians… – Continue reading

Singapore Updates Guidance On Transfer Pricing Regime

The Inland Revenue Authority of Singapore (IRAS) on February 23, 2018, released the fifth edition of its Transfer Pricing Guidelines for income tax. During a public consultation held in June 2017, stakeholders asked the Ministry of Finance to provide more clarity and guidance on transfer pricing documentation (TPD) requirements, specifically… – Continue reading

India, Kenya revise tax treaty

NEW DELHI: The Indian and Kenyan governments have revised their double taxation avoidance agreement (DTAA) to bring down the withholding tax rates, protect treaty from abuse and check tax evasion, an official statement said on Thursday. The revised DTAA was notified on February 19, said a Finance Ministry statement. “The… – Continue reading

Senate ratifies cybercrime, tax treaties

The Senate on Monday passed on third and final reading five resolutions concurring the ratification of five treaties, including the Budapest Convention on Cybercrime which would prevent syndicates from making the Philippines a “haven” for their illegal activities. Senators also unanimously ratified four treaties covering the Philippines’ Double Taxation Avoidance… – Continue reading

India, Iran ink pact to avoid double taxation, prevent fiscal evasion

India and Iran today signed an agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with regard to taxes on income. The agreement is on similar lines as entered into by India with other countries, the Central Board of Direct Taxes (CBDT) said in a statement. “The agreement… – Continue reading

Kazakhstan ratifies amendments to double taxation convention with India

ASTANA. KAZINFORM Kazakhstan has ratified the Protocol between the Governments of Kazakhstan and India on introducing amendments to the Convention on the avoidance of double taxation, the press service of Akorda reports. Head of State Nursultan Nazarbayev signed the Law of the Republic of Kazakhstan “On Ratification of the Protocol… – Continue reading

Sherman Secures Treasury’s Commitment to Pursue U.S.-Armenia Double Tax Treaty

Secretary Mnuchin Commits During Congressional Testimony to Assign Treasury Department Officials to Work on Bilateral Accord WASHINGTON—Treasury Secretary Steven Mnuchin, during Congressional testimony Tuesday before the U.S. House Financial Services Committee, agreed – in response to direct questioning by Representative Brad Sherman (D-CA) – to commit Treasury Department officials to… – Continue reading

Netherlands Confirms Tax Treaty Negotiation Priorities

The Netherlands will seek to resume discussions towards double taxation avoidance treaties with several countries in 2018, including the United States, the Government has said. The Dutch Government will attempt to begin tax treaty talks with at least seven countries this year, including Australia, Colombia, Costa Rica, Ecuador, Morocco, Austria,… – Continue reading

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading

Valadao and Sherman call on Treasury to stop double taxation of U.S.-Armenia profits

U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading

Greece Raises BEPS Concerns With Bulgaria

The heads of the Greek and Bulgarian tax authorities have met to discuss ways in which bilateral cooperation can be boosted with a view to reducing levels of tax avoidance and evasion, particularly with respect to Greek companies shifting profits to Bulgaria. “The major issue of tax avoidance by Greek… – Continue reading

India Signs Three Further APAs During December

India entered into three more advance pricing agreements in December, with two unilateral agreements and a bilateral APA concluded with authorities in the United Kingdom. With the signing of these agreements, the total number of APAs entered into by the Central Board of Direct Taxes totals 189, comprising 173 unilateral… – Continue reading

Thousand billions in lost tax from foreign enterprises

Vietnam has lost thousands of billions of dong in taxes as foreign enterprises, especially large-scale ones, refuse to pay based on the Double Taxation Avoidance Agreement. Massive revenue without having to pay taxes The Ho Chi Minh City Department of Taxation has recently issued an ultimatum for Uber B.V Netherlands… – Continue reading

Taiwan-Czech Republic ink double taxation avoidance pact

An agreement between Taiwan and the Czech Republic on double taxation avoidance and fiscal evasion prevention with respect to taxes on income was concluded Dec. 12 in Prague, setting the stage for increased investment and trade as well as industrial and technological cooperation between the two countries, according to the… – Continue reading

Proposed new UK royalty withholding tax will apply from April 2019

A new royalty withholding tax will apply from April 2019 where a non-UK resident entity making sales in the UK pays a royalty to a connected party in a low tax jurisdiction, according to a consultation document which sets out further details of the proposal, which was first announced in… – Continue reading

Hong Kong Finalizes FTA with ASEAN, DTAA with India

Hong Kong recently finalized a series of agreements that, taken together, shift Asia’s trade and investment landscape. On November 12, Hong Kong and ASEAN signed the ASEAN-Hong Kong, China Free Trade Agreement (AHKFTA), and the ASEAN-Hong Kong Investment Agreement (AHKIA). Prior to this, on November 10, Hong Kong and India… – Continue reading

Revised tax treaty to boost bilateral investment: Cyprus envoy

Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading

NA passes Bhutan-Bangladesh double tax avoidance agreement

The National Assembly endorsed the double taxation avoidance agreement between Bhutan and Bangladesh yesterday. Signed during the visit of Bangladesh Prime Minister Sheikh Hasina to Bhutan in April 2017, the agreement plans to do away with double taxation of incomes between the two countries. In the presence of 38 MPs,… – Continue reading

East African states to ratify double taxation treaty to boost integration

NAIROBI, Nov. 16 (Xinhua) — The East African Community (EAC) member states are set to ratify the avoidance of double taxation treaty in order to boost regional integration, a Kenyan official said on Thursday. Barrack Ndegwa, Regional Integration Secretary in the Ministry of EAC, Labor and Social Protection, told Xinhua… – Continue reading

Govt. of India and Govt. of NZ signs Third Protocol to the Convention for avoidance of double taxation and the prevention of fiscal evasion

The Ministry of Finance (Department of Revenue) vide notification S.O. 3512(E) dated November 2, 2017 sets out the Third Protocol to the Convention between the Government of the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with… – Continue reading

Cabinet Gives Nod To Signing Double Taxation Avoidance Agreement With Hong Kong

The Cabinet today gave its green light to an agreement between India and the Hong Kong Special Administrative Region (HKSAR) of China for avoiding double taxation and prevention of tax evasion. The Cabinet, chaired by Prime Minister Narendra Modi also approved the protocol amending the agreement between India and Kyrgyzstan… – Continue reading

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… – Continue reading

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading

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… – Continue reading

U.S. not going to abolish double taxation with Armenia: envoy

PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading

Japan, Estonia Sign Double Tax Treaty

Japan and Estonia signed a convention to eliminate double taxation on cross-border trade and investment on August 30. The treaty sets out the taxing rights of both countries on cross-border income deriving from investment or trade between the two. It also provides for assistance in the collection of tax and… – Continue reading

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… – Continue reading

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading

Singapore, Ghana Sign New Double Tax Treaty

The DTA clarifies the taxing rights on all forms of income flows arising from cross-border business activities and seeks to ensure such income is not taxed twice. The agreement provides that withholding taxes on dividends, interest, and royalties will generally not exceed seven percent. Withholding taxes on service fees will… – Continue reading

UK-UAE treaty means UK pension free of income tax

Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading

Ukraine ratified double tax treaty with Luxembourg

On 14 March 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg “On Avoidance of Double Taxation and Prevention of Income and Capital Tax Evasion” (the “Convention”) and a protocol to it (the “Protocol”). As we informed… – Continue reading

UK To Expand Double Tax Treaty Passport Scheme

HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading

Irish Citizen Denied US Tax Refund On Gambling Winnings

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading

Netherlands, Uzbekistan Sign Anti-Abuse Agreement

The Netherlands has signed a protocol to its double tax avoidance treaty with Uzbekistan, designed to prevent the treaty from being inappropriately used to avoid taxes. The anti-abuse provision was signed by the Netherlands and Uzbekistan on February 7, 2017, and “prevents the benefits of the treaty only [being] used… – Continue reading

ANCA and Senator Menendez Discuss Benefits of a U.S.-Armenia Double Tax Treaty

Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral… – Continue reading

Opportunity for Refund of Late Interest charged on Failed Withholding Tax Notifications

Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading

UK: UK – UAE Double Tax Treaty Now In Force – What You Need To Know

The signing of a double taxation agreement between the UK and the UAE in April 2016 was undoubtedly much anticipated and marks a new milestone in the successful expansion of the UAE’s international tax treaty network. Following ratification of the agreement by the two countries reacting parties, it came into… – Continue reading