Category: DTA

Denmark / DTA / Greenland / Hong Kong / Iceland / Norway / Sweden / Tax Information Exchange Agreements

Orders on tax information exchange agreements with Nordic jurisdictions and protocol on avoidance of double taxation arrangement with the Mainland gazetted

Posted On: October 2, 2015

Hong Kong (HKSAR) – Six orders for implementing the tax information exchange agreements (TIEAs) with six Nordic jurisdictions (i.e. Denmark, the Faroes, Greenland, Iceland, Norway and Sweden), and an order for implementing the Fourth Protocol to the Comprehensive Arrangement for the Avoidance of Double Taxation with the Mainland (the Arrangement)… – Continue reading

Court cases / DTA / India / Mauritius / Offshore Companies / Permanent establishment / Singapore

SC to hear Castleton Investment case against MAT levy tomorrow

Posted On: September 29, 2015

The court agrees to an early hearing in the case, scheduling it for 30 September New Delhi: The Supreme Court on Tuesday agreed to an early hearing in the case of Castleton Investment Ltd scheduling it for 30 September. Castleton Investment, a Mauritius-based foreign company, is contesting a case against… – Continue reading

Automatic Exchange of Information / Common Reporting Standard / DTA / EU / Europe / FATCA / G20 / OECD / Offshore Tax Evasion / Residence / Tax Laws / Tax Planning / USA

The Common Reporting Standard: Automatic Information Exchange Goes Global

Posted On: September 25, 2015

Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading

Capital gains / DTA / India / Offshore Companies / Permanent establishment

Foreign Firms Get Retrospective Relief From Controversial Tax

Posted On: September 24, 2015

In a big relief to foreign firms, the government on Thursday exempted them from paying minimum alternate tax (MAT) retrospectively from April 2001, provided they did not have a permanent establishment in India. Tax experts said that this government move ends a lot of uncertainty on the controversial MAT issue… – Continue reading

Capital gains / DTA / India / Offshore Companies / Permanent establishment

Centre to exempt foreign firms covered by double taxation treaty

Posted On: September 24, 2015

IT Act will be amended with retrospective effectto exempt foreignfirms from MAT In a big relief to foreign firms, government on Thursday said the Income Tax Act will be amended with retrospective effect to exempt from minimum alternate tax (MAT) the overseas companies that covered under double taxation avoidance agreements… – Continue reading

China / DTA / Hong Kong / India / Investments

FIIs seek ease of doing biz

Posted On: September 22, 2015

Foreign institutional investors (FIIs) on Monday sought simplified requirements for making investments in India, during their meeting with Finance Minister Arun Jaitley. Jaitley, who has wrapped up his two-day visit here, highlighted recent initiatives taken by the government to attract investments and told them, efforts were being taken to further… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / Capital gains / Dividends / DTA / Ghana / Investments / Legislation / Memorandum of Understanding (MoU) / Netherlands / OECD / Tax Laws / Tax treaties / Transfer pricing / Treaty Abuse

BEPS for beginners – Preparing to comply

Posted On: September 22, 2015

As discussed in the previous edition, due to current worldwide developments including the OECD’s move to curb tax Base Erosion and Profit Shifting (BEPS), tax policy is changing significantly. In Ghana for example, a Transfer Pricing Regulations was passed in 2012 which aimed to ensure that the tax base of… – Continue reading

Australia / DTA / Israel

Israel and Australia to negotiate tax treaty

Posted On: September 17, 2015

Australian Treasurer Joe Hockey: Australian companies can take greater advantage of Israel’s knowledge-based economy. There is no tax treaty between Australia and Israel, but the lack will soon be made good, according to an announcement by Joe Hockey, Treasurer in the Australian government. “As part of the Government’s ongoing efforts… – Continue reading

China / DTA / Financial markets / Hong Kong / Japan / Offshore Banking / Singapore / United Kingdom / USA

HK Report Suggests Tax Incentives For Booking Centers

Posted On: September 17, 2015

Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading

Africa / Axa / DTA / Investments / Nigeria / Seychelles

Nigeria: Seychelles-Nigeria Investment Forum Expected to Boost Trade Says Outgoing Nigerian High Commissioner to Seychelles

Posted On: September 15, 2015

Victoria Seychelles — Promoting cooperation between African countries and increasing trade and industry have been the main focus of diplomatic work of the outgoing Nigerian High Commissioner to Seychelles, Solomon Akintola Oyateru, during his term in office. High Commissioner Oyateru made this statement in an interview with the press at… – Continue reading

Automatic Exchange of Information / Barbados / Common Reporting Standard / Cyprus / DTA / EU / FATCA / G20 / IMF / Italy / OECD / Offshore Investments / Tax Planning

Not international business as usual

Posted On: September 12, 2015

BARBADOS’ OFFSHORE FINANCIAL SERVICES SECTOR is again under threat. The Organisation for Economic Cooperation and Development (OECD), G20 and the European Union (EU) are acting in concert, armed with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Once implemented, the confidentiality which once protected financial… – Continue reading

Beneficial Ownership / Capital gains / China / Dividends / DTA / Permanent establishment / Royalties / Shares / Taiwan

Agreement between Mainland China and Taiwan to avoid double taxation on income

Posted On: September 10, 2015

On August 25, 2015, the People’s Republic of China and Taiwan signed an Agreement for the Avoidance of Double Taxation regarding Taxes on Income (“the DTA”), which will enter into force when the legal procedures have been completed. The DTA’s highlights: 1. Permanent establishment (“PE”) specifications The DTA establishes a… – Continue reading

Argentina / Brazil / Chile / China / DTA / Investments / Mexico / Peru / South America / Venezuela

Venezuelan President’s Visit to China Indicative of Growing Sino-Latin American Trade and Opportunities

Posted On: September 10, 2015

On September 1, Venezuelan President Nicolas Maduro arrived to Beijing in an effort to strengthen economic ties between Venezuela and China. In his second visit this year, the Venezuelan President signed a number of deals that will strengthen cooperation in new areas beyond the current focus on the oil industry…. – Continue reading

Chile / Curacao / DTA / Germany / Hong Kong / Investments / Ireland / OECD / Singapore / USA

The Case For A Territorial Tax Regime For Curaçao

Posted On: September 10, 2015

Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading

Andorra / DTA / Greenland / San Marino / Seychelles / Switzerland / Tax Information Exchange Agreements

Another four tax information exchange agreements now in force

Posted On: September 9, 2015

Bern, 09.09.2015 – The tax information exchange agreements with Andorra, Greenland, San Marino and the Seychelles have come into force. They will apply from 1 January 2016. Following the completion of the corresponding ratification processes, the tax information exchange agreements (TIEA) have come into force with Andorra (27 July 2015),… – Continue reading

Beneficial Ownership / Capital gains / Cyprus / Dividends / DTA / OECD / Residence / Royalties / South Africa

Cyprus: The New Protocol To The Cyprus–South Africa Double Taxation Agreement

Posted On: September 9, 2015

On April 1, 2015, Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since December 8, 1998. At the time the original DTA was concluded, dividends arising in South Africa were not subjected to South… – Continue reading

Capital gains / Cyprus / Dividends / DTA / Royalties / Tax Information Exchange Agreements / Ukraine

Cypriot Ministry of Finance announces a Protocol amending the DTA between Cyprus and Ukraine after its expiry has been concluded

Posted On: September 8, 2015

On September 8, 2015 the Cypriot Ministry of Finance published an announcement titled: “Conclusion of a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income between the Republic of Cyprus and the Government of Ukraine… – Continue reading

China / DTA / FATF / G20 / Guernsey / High Networth Individuals / Hong Kong / IMF / Intellectual Property / Investments / Legislation / Ma Yun / Memorandum of Understanding (MoU) / OECD / Offshore Trusts / Real Estate / Singapore / Tax Information Exchange Agreements / Tax Planning / United Kingdom / USA

Guernsey: What Guernsey Can Offer Chinese HNWIs’

Posted On: September 8, 2015

In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading

Automatic Exchange of Information / DTA / France / HSBC / India / Legislation / Luxembourg / OECD / Switzerland / Tax evasion investigations

New Swiss Banking Norms May Not Help India’s Hunt for Black Money

Posted On: September 8, 2015

Switzerland will allow stolen data acquired through official means to form the basis for a request for assistance but will help India only for post-2011 bank accounts, that too as long as Swiss courts don’t interfere Geneva: Switzerland’s proposed changes on treating stolen information have generated much optimism in India… – Continue reading

Australia / Beneficial Ownership / British Virgin Islands / Court cases / DTA / South Africa / Tax treaties

Ex parte preservation orders: Krok v CSARS

Posted On: September 7, 2015

This case was an appeal from the Gauteng Division of the High Court to the Supreme Court of Appeal (“SCA”) pertaining to the correctness of the granting of an ex parte preservation order application that was brought against Mr Krok by the Commissioner of the South African Revenue Service (“SARS”) in… – Continue reading

Channel Islands / DTA / EU / Gibraltar / Investments / Isle of Man / Legislation / Thailand / United Kingdom

Phuket Expat Finance: QROPS – Back to Basics

Posted On: September 6, 2015

PHUKET: In 2005 the EU Commission proposed a directive that laid the foundations for a radical change in the portability of an individual’s pension. British, Dutch and Irish nationals were given the flexibility to move certain private pensions to the jurisdiction of their choice, rather than leave it in their… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / DTA / Germany / India

India, Germany to resume talks on DTAA revision

Posted On: August 29, 2015

India and Germany have agreed to resume negotiations on partial revision of double taxation avoidance agreement (DTAA), the government said on Friday. The two countries have agreed to explore possibilities of enhancing tax related information while continuing to share information on the basis of existing agreements, the ministry of finance… – Continue reading

Automatic Exchange of Information / Barbados / DTA / FATCA / Italy / USA

Inniss optimistic about Barbados’ removal from blacklist

Posted On: August 24, 2015

MINISTER OF INTERNATIONAL Business, Donville Inniss is optimistic that given Barbados’ and Italy’s continued efforts at strengthening bilateral relations, Barbados could soon be removed from Italy’s blacklist. He made this disclosure this morning during his brief remarks at the end of a signing of a Double Taxation Agreement (DTA) between… – Continue reading

Anti money laundering / DTA / HSBC / India / Mauritius

Confusion over Modi’s I-Day speech: DTAA info behind Rs 6,500 cr disclosure on black money

Posted On: August 20, 2015

Many have, mistakenly, confused the prime minister (PM)’s recent remark that Rs 6,500 crore had been disclosed by holders of hitherto unaccounted money with disclosures under the compliance window in the recent law on the subject. However, this money has nothing to do with the latter’s three-month window. These came… – Continue reading

Capital gains / Cyprus / Dividends / DTA / OECD / Residence / South Africa

Cyprus: The New Protocol To The Cyprus – South Africa Double Taxation Agreement

Posted On: August 19, 2015

On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading

Boeing / DTA / Germany / India / USA

Aircraft overhaul expenses continue to be “fees for technical services” but not taxable absent source in India

Posted On: August 18, 2015

In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading

Dividends / DTA / Ethiopia / Fees / Permanent establishment

Polish Ministry of Finance publishes the text of the DTA that was recently concluded with Ethiopia

Posted On: August 13, 2015

The Polish Ministry of Finance has published the text of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as concluded on July 13, 2015 between The Republic of Poland and the Federal Democratic Republic of Ethiopia (Hereafter: the… – Continue reading

Capital gains / Denmark / DTA / France / Germany / Ghana / Investments / Italy / Tax evasion investigations

Gov’t, Denmark reach double taxation deal

Posted On: August 12, 2015

The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading

Barbados / Bulgaria / Croatia / Cyprus / DTA / Estonia / EU / Finland / Greece / Italy / Latvia / Lithuania / Poland / Portugal / Slovenia / Spain

Spain removes Barbados from blacklist

Posted On: August 10, 2015

FOLLOWING A PROTEST from the Ministry of International Business, Spain has removed Barbados from its tax blacklist. This latest development comes after a recent decision was taken by members of the European Union to blacklist this country for being a non-cooperative tax jurisdiction. International Business Minister, Donville Inniss, praised the… – Continue reading

Beneficial Ownership / Capital gains / Cyprus / Dividends / Double Taxation / DTA / Georgia / OECD / Permanent establishment / Residence / Royalties

Cyprus: The New Double Taxation Agreement Between Cyprus And Georgia

Posted On: August 5, 2015

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

Dividends / DTA / Europe / Investments / Kuwait / Oman / Qatar / Switzerland / Tax Information Exchange Agreements / Visa

Double taxation pact reflects growing importance of Oman: Swiss envoy

Posted On: August 5, 2015

Muscat – H E Christian Winter, Switzerland’s Ambassador to Oman has said that the recently signed Double Taxation Agreement (DTA) between his country and the sultanate reflects the broader ties Switzerland seeks with GCC. “The conclusion of the agreement takes into account the growing economic and political importance of the… – Continue reading

Capital gains / Dividends / DTA / EU / Europe / Germany / Offshore Investments

Germany: Taxation of Foreign Investment in Germany

Posted On: August 5, 2015

Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading

Double Taxation / DTA / EU / France / Legislation / Royalties / United Kingdom

EC Will Not Challenge Member States On Royalties Tax

Posted On: August 5, 2015

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

Corruption / DTA / India / Switzerland / Tax evasion investigations

From IPL to Swiss money to tax-havens; New book on black money tells all

Posted On: June 28, 2015

NEW DELHI: Anecdotes about the first Income Tax searches in the T-20 IPL cricket tournament and a letter by former Finance Minister P Chidambaram seeking information about alleged illegal accounts by Indians in Switzerland find place in a new book on black money. The recently launched book “It’s Raining Black!… – Continue reading

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