Category: Double Taxation

Singapore and France revise their tax convention

Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading

Multinationals yearn for better service

Firms need clear rules, certainty to remain in compliance with tax law, says expert Heightened scrutiny of foreign companies’ tax practices is a sign of China’s effort to modernize its taxation system to keep up with the fast-changing international business environment, but there is another dimension that concerns the foreign… – Continue reading

The major Irish firms in tax haven territory

Some of the biggest listed Irish firms have subsidiaries in so-called ‘tax havens’, like the British Virgin Islands, Jersey or Luxembourg. They say it’s not to reduce their tax bills – so why are they there? The subsidiaries are registered in well-known offshore tax havens, such as the British Virgin… – Continue reading

The art of not curbing investment

If the Davis tax committee’s recommendations are followed, tax avoidance could be effectively reined in. Zeroing in on the super-wealthy and tax reluctant remains at the top of the global agenda as budgets across the world grow increasingly hungry for extra revenues. Now a draft report from the Davis tax… – Continue reading

Singapore inks tax agreements with France and Uruguay

SINGAPORE: Singapore has signed agreements with France and Uruguay for avoidance of double taxation (DTA). In the agreement with France, the revised DTA offers improved terms for businesses, such as lower withholding tax rates for dividends and includes anti-abuse provisions. The signing took place in Singapore between Singapore Deputy Prime… – Continue reading

Budget 2015 India: Clarity on tax issues key for IT industry, say brokerages

Allowance of bilateral treaty for advanced pricing agreement should help mitigate issues around double taxation of income, feels brokerage house Morgan Stanley Moneycontrol Bureau Clarity around definition of export turnover and total turnover for computation of tax exemption in the Budget will help resolution of tax-related disputes, says brokerage house… – Continue reading

FactCheck: is Australia’s corporate tax rate not competitive with the rest of the region?

“Well, Jon, the Government’s about to bring in a 1.5% corporate, or company, tax cut from the 1st of July. That’s something that obviously we support, because (the) corporate tax rate at 30% is not competitive with the rest of the region and we need to drive that down.” –… – Continue reading

ICC calls on G20 Finance Ministers to accelerate implementation of the Brisbane Action Plan and National Growth Strategies

The International Chamber of Commerce (ICC) joined discussions today with G20 Finance Ministers and Central Bank Governors to set priorities for continued economic growth during the Turkish G20 presidency. As part of Turkey’s G20 platform for inclusiveness, implementation, and investment – the three I’s of the government’s G20 2015 presidency… – Continue reading

The rise of pass-throughs

Call it the pass-through revolution. The U.S. has been losing about 60,000 conventional corporations a year, according to the Tax Foundation. It’s lost 1 million since 1986, the foundation said. Meanwhile, the number of pass-through entities has exploded. “More than 60 percent of U.S. business profits are now taxed under… – Continue reading

Sharing tax details: door for dialogue still open, says Swiss Finance Ministry

NEW DELHI, FEBRUARY 9: The “door for dialogue” with India remains open despite the current “difficult environment” on the tax-related information sharing front, the Swiss Finance Ministry has said. In a just released annual report on International Financial and Tax Matters 2015, Switzerland has admitted that its relations with India… – Continue reading

AICPA Urges Senate to Act on International Income Tax Treaties

The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading

India, US set to map out way to end transfer pricing cases in court

More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading

Hong Kong’s new and impossible rules for obtaining tax treaty residency certificates

On 29 January 2015, the Hong Kong Inland Revenue Department (“IRD”) announced new, hard-line procedures for obtaining a certificate of Hong Kong resident status (“tax residence certificate”) for the purpose of Hong Kong’s comprehensive double taxation agreement (“DTA”) network. The new rules became effective on 1 February 2015. This Client… – Continue reading

OECD will update G20 finance ministers on BEPS project implementation next week

G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading

Croatia: UK And Croatia Signed Double Taxation Avoidance Agreement

Croatia and the UK have signed an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains. The Agreement was duly signed on January 15th, 2015 and it shall enter into force when both countries complete their… – Continue reading

Businessmen welcome Indonesia’s tax amnesty plan

The Indonesian Employers Association (Apindo) has welcomed the government’s plan to introduce a tax amnesty, a fiscal incentive expected to encourage individuals or corporation that have not fully paid their taxes to comply with tax regulations. The association’s deputy chairman Hariyadi Sukamdani said that the amnesty would be effective in… – Continue reading

We pay our fair share of tax and create jobs, say Google and Apple

Technology giants Apple and Google have said in their submissions to the federal inquiry into corporate tax avoidance that they support international changes to global tax rules to stop profit shifting, but have warned of the risk of Australia acting alone, saying it would cost heavily in local jobs and… – Continue reading

North Korea making agreements for foreign investment

Though North Korean labor more expensive than previously thought – RFA The DPRK government made agreements promoting mutual investment and preventing double taxation for foreign investors, particularly highlighting cooperation with Russia, according to an article from the Korean Central News Agency (KCNA) published this week. Governments often form tax treaties… – Continue reading

Taxpayers No Longer

Some 776 American citizens or long-time residents renounced their status in the third quarter of 2014, according to the Treasury Department. If that trend continues, the U.S. will see more than 3,000 renunciations this year-a record. Why are so many Americans forfeiting their citizenship? In 2010, Congress passed the Foreign… – Continue reading

Kenya: Don’t Double Tax – Rotich

NATIONAL Treasury Cabinet Secretary Henry Rotich has urged counties to make taxation systems business friendly. Speaking at Leisure Lodge resort in Kwale yesterday during a county government development forum, Rotich said investors face multiple taxation in some counties. “It is very clear what the national government and counties are supposed… – Continue reading

Belgian Tax Breaks for Multinational Companies Probed by EU

(Bloomberg) — The European Union is investigating Belgium’s tax deals with multinational corporations, potentially dragging dozens more companies into widening probes of sweetheart fiscal pacts handed out by national governments. Building on investigations of Apple Inc. in Ireland and Amazon.com Inc. in Luxembourg, the European Commission is targeting Belgium’s so-called… – Continue reading

BEPS feedback highlights a lack of taxpayer confidence in the OECD’s work on double taxation and dispute resolution

Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. The OECD’s BEPS project was the TP topic of 2014 and will undoubtedly retain the top… – Continue reading

Africa loses $50bn in illicit finance flows

Weak governance means Africa loses more than $50bn each year in unpaid taxes and money laundering, a new report has found. The analysis, published jointly by the African Union and the United Nations Economic Commission for Africa, concluded that a lack of financial transparency and difficulties in obtaining systematic data… – Continue reading

DTAA: How will help it India & US taxpayers?

India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading

French tax update: new China – France double tax treaty, amendment to Singapore – France double tax treaty, noteworthy tax courts decisions and administrative publications

The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading

23 FDI proposals deferred for possible tax treaty abuse

NEW DELHI: Getting tough with investment proposals from tax heavens, FIPB has deferred 23 applications in its last three meetings apprehending “treaty abuse”. According to sources, the Department of Revenue has expressed doubt that a few foreign companies were evading tax by routing their investments through tax heaven countries with… – Continue reading

Massie: Stop taxing Social Security recipients

NKY congressman says that current system amounts to ‘double taxation’ on people. His bill could save some seniors thousands of dollars. Are you a higher-income Social Security recipient who must pay federal taxes on your benefits? U.S. Rep. Thomas Massie is your friend. Massie, R-Garrison, last week introduced the latest… – Continue reading

Merge inheritance tax and capital gains tax, says Institute of Directors

Capital Gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, IoD suggests Capital gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, according to the Institute of Directors. Taxes raising less than £5billion a year should be merged… – Continue reading

Nepal, Bangladesh to sign DTAA

KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading

Nepal, Bangladesh to sign DTAA

KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

Global Tax Transparency Rising in 2015 As FATCA, OECD Initiatives Gain Momentum

Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading

January Global Tax-News Update

This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading