Category: DTA

Singaporean – Ecuadorian DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Ecuador for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Singaporean – San Marinese DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of San Marino for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Singaporean – Seychellois DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Mohammed receives Slovak Prime Minister

His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, on Monday received Robert Fico, Prime Minister of Slovakia, and members of the accompanying delegation at Zabeel Palace. During the meeting, Sheikh Mohammed accepted an invitation from the Slovak prime minister… – Continue reading

Swiss, Italy agree deal on taxing cross-border commuters

ZURICH: Negotiators from Switzerland and neighbour Italy reached agreement on Tuesday on how to tax cross-border commuters, wrapping up months of talks that aimed to help Italy crack down on undeclared foreign wealth. The accord, which must be approved by both national governments and parliaments, would see workers paying up… – Continue reading

SARS Explains 2015 Tax Administration Amendments

On December 17, the South African Revenue Service (SARS) issued an explanatory memorandum on the 2015 Tax Administration Laws Amendment Bill (TALAB). In particular, the memorandum looks at the TALAB provisions giving effect to the collection of information from South African financial institutions (FIs), and the associated obligation on the… – Continue reading

Andorra, Malta Sign Double Tax Agreement

Andorra and Malta have signed an agreement on the avoidance of double taxation and prevention of fiscal evasion. The Government of Andorra announced on December 16 that, following two days of meetings, an agreement was signed between a delegation led by Andorra’s Secretary of State for International Financial Affairs, Claudia… – Continue reading

Double taxation avoidance

India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading

DYK: Dividend from investing in shares of foreign companies is taxable in India

Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading

An Overview of Transfer Pricing in Vietnam

Transfer pricing is a tax planning method where related companies enter into transactions among each other to shift funds, and thereby profits. For instance, a parent company can extract funds from a subsidiary by having the issue a dividend, but the parent can also provide a service to subsidiary and… – Continue reading

ATAF pushes for scrapping of double taxation

THE African Tax Administration Forum (ATAF) has come up with a draft document on avoidance of double taxation and prevention of fiscal evasion within the continent. The Zimbabwe Revenue Authority (Zimra), a member of ATAF, has said avoidance of taxation and prevention of fiscal evasion was with respect to taxes… – Continue reading

Business Brief – Double Tax Agreement – Residence – change of HMRC practice

Following an agreement between the UK and Jersey, HMRC has published an important change of interpretation on residence for treaty purposes. HMRC’s view now is that the better interpretation of residency article in the UK-Jersey Double Tax Agreement 1952 (“UK Jersey DTA”) is that it includes a tie breaker provision… – Continue reading

Russian government approves draft double taxation agreement with Hong Kong

The draft agreement is intended to settle the issue of taxation of business profit, property revenues, sea and air transportation earnings, passive revenues and individual income MOSCOW, December 10. /TASS/. The Russian Government approved the draft intergovernmental agreement with Hong Kong on avoidance of double taxation and prevention of tax… – Continue reading

India, Switzerland improve cooperation on tax matters

NEW DELHI: With India stepping up efforts to bring back illicit funds stashed abroad, Switzerland has said both sides have improved their cooperation on tax matters following several high-level meetings. Over the past few months, both countries have been working closely on mutual administrative assistance, according to the Swiss government…. – Continue reading

Azerbaijan, Israel should pay much attention to private sector for constructive ties (exclusive)

By Anakhanum Khidayatova – Trend: A lot should be left to the private sector to achieve constructive relations between Azerbaijan and Israel, according to Dan Stav, Israeli ambassador in Baku. “In order to encourage business in each country, you need to create conducive environment,” he said speaking to Trend Dec…. – Continue reading

India and South Korea sign taxation treaty MoU

NEW DELHI: India and Korea have inked a new memorandum of understanding on suspension of collection of taxes during pendency of mutual agreement procedure. This MoU will relieve the burden of double taxation for taxpayers in both the countries during the pendency of MAP proceedings. MAP or Mutual Agreement Procedure… – Continue reading

Tax amendments – 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly… – Continue reading

HMRC changes view on the company residence tie-breakers in certain double tax agreements

HMRC has reached an agreement with Jersey concerning the interpretation of the company residence tie-breaker in the Jersey-UK 1952 double tax agreement. This change also affects the interpretation of 15 other double tax agreements (DTAs) which have identical or very similarly worded company residence tie-breakers. The issue concerns dual residents… – Continue reading

Singapore displaces Mauritius as top FDI source

Singapore has displaced Mauritius as the top source of foreign direct investment (FDI) in India during the first half of this fiscal. Figures compiled by the Department of Industrial Policy and Promotion show that during April-September, India attracted $6.69 billion (Rs 43,096 crore) FDI from Singapore and $3.66 billion (Rs… – Continue reading

Swaraj calls on Mauritius Prez, discusses range of issues

External Affairs Minister Sushma Swaraj today called on Mauritius President Ameenah Gurib-Fakim and discussed a range of issues of mutual interest including impediments to investment inflows. Gurib-Fakim, the first woman President of Mauritius, who is a distinguished scientist, arrived here yesterday on a three-day visit. In the meeting, Gurib-Fakim and… – Continue reading

Chinamasa hails China mega deals

Ellah Mukwati Herald Correspondent The recent historic visit by the Chinese President Xi Jinping which saw 12 mega deals worth $4 billion being signed cemented the good bilateral relationship between Zimbabwe and China, the Minister of Finance and Economic Development has said. In a statement released yesterday Minister Patrick Chinamasa… – Continue reading

Government looks to rework DTAA tax provisions

Some of the DTAAs entered into by India with other countries allow taxation of capital gains on shares only in the country of which the taxpayer is a resident. The government on Friday told the Lok Sabha that it has started negotiations with some countries to amend provisions on capital… – Continue reading

Tax Revenue Loss due to Avoidance and Tax Planning by Companies

The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading

India-Mauritius tax treaty revision talks on, says Tax official

Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading

Non-disclosure of foreign assets could turn risky for taxpayers: Jayant Sinha

NEW DELHI, DEC 3: Domestic taxpayers would do well to fully disclose their foreign assets with Indian tax authorities, Jayant Sinha, Minister of State for Finance, has said. Non-disclosure of foreign assets could turn a “risky” proposition for taxpayers, Sinha said in his inaugural address at the 6th meeting of Automatic… – Continue reading

GOVT TO PAY OUTSTANDING $300M TO PTA BANK

By SYLVESTER MWALE – THE Government has resolved to liquidate the outstanding US$300 million owed to Eastern and Southern African Trade and Development (PTA) Bank accumulated through petroleum importation. The arrears would be dismantled in four installments within a period of one year. Chief Government Spokesperson Chishimba Kambwili said in… – Continue reading

UK Gov’t Amends View On DTA Residence Articles

UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs). The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in their 1952 DTA…. – Continue reading

Iran, Hungary ink 8 coop. documents

TEHRAN, Nov. 30 (MNA) – Islamic Republic of Iran and Hungary signed eight cooperation documents for widening and deepening of relations. During his visit to Tehran, Hungary’s Prime Minister Viktor Orban, heading a group of 120 economic activists, businessmen and officials from the European country’s banks, and Iranian side signed… – Continue reading

Formula One seeking to encash $15.45-million guarantee by Jaiprakash Associates

MUMBAI: Formula One is seeking to encash a $15.45-million guarantee by debt-laden Jaiprakash Associates BSE 1.18 % on the ground that it hadn’t paid the sport’s organiser money that had been contractually agreed upon. The company said the amount is caught up in tax litigation and hence can’t be given…. – Continue reading

Kenya and South Africa tax deal takes effect in January

The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading

N/Assembly to domesticate all pending Treaties, MoUs- Dogara

Abuja – The speaker of the House of Representatives, Rt. Hon Yakubu Dogara, yesterday reiterated the resolve of the legislature to domesticate all pending treaties, memoranda of understanding and agreements that will bring benefit to Nigerians. Dogara said this while speaking to a Korean delegation that paid him a courtesy… – Continue reading

Mauritius and Morocco Sign Double Taxation Avoidance Agreement

PRESS RELEASE Mauritius and Morocco signed on November 25 in Port Louis a Double Taxation Avoidance Agreement (DTAA) that will provide for greater tax certainty for businessmen of the two countries. The signatories were the Minister of Finance and Economic Development, Mr Vishnu Lutchmeenaraidoo, and the Ambassador of the Kingdom… – Continue reading

Worldwide: Final BEPS Reports Issued By OECD

The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading

Overview of transfer pricing in Hong Kong and China

Introduction Transfer pricing is a term used to define the price charged between associated enterprises for the transfer of goods, services and intangible property. Increasing cross-border activities have made transfer pricing a real issue as enterprises seek to use transfer pricing as a tool for tax avoidance. Consequently, HK has… – Continue reading

India: Foreign Companies Without Permanent Establishment: Freed From MAT Provisions

The Central Board of Direct Taxes (CBDT), Government of India, via press release dated September 24, 2015, assured the inapplicability of Minimum Alternate Tax (MAT) provisions to Foreign Companies with effect from 01.04.2001. The Government recently issued a circular, accepting the recommendations of the Committee (A P Shah Committee) appointed… – Continue reading

SWISS TAX DEPARTMENT DISCLOSES NAME OF CONGRESS LEADER, HER SON, INDIA SEEKS

The number of Swiss institutions have seen “asset outflows” and the tax status of many of their clients have been found to be “inappropriate”, as per the Swiss Financial Market Supervisory Authority (FINMA), which also has the mandate to combat money laundering activities. Switzerland authorities revealed on Tuesday that India… – Continue reading