Category: Tax treaties

Jubilant Food Works Limited is not a PE of Domino’s Pizza International Franchising Inc: ITAT [Read Order]

In DCIT vs. M/s. Dominos Pizza International Franchising Inc., the Mumbai Bench of the Income Tax Appellate Tribunal ( ITAT ) held that Jubilant Food Works Limited, who holds the Master Franchise for Domino’s Pizza in India is not a Permanent Establishment of the Domino’s Pizza International Franchising Inc. In… – Continue reading

FBR set to receive 50,000 cases of Pakistanis owning assets abroad

ISLAMABAD: Pakistan’s tax authorities have placed standardised software for receiving first batch of around 50,000 cases of Pakistanis owning assets and bank accounts abroad through automatic exchange portal from Organisation for Economic Cooperation and Development (OECD) with effect from October 1. Top officials in the Federal Board of Revenue (FBR)… – Continue reading

Ghana Parliamentary Minority raises red flag over Double Taxation Agreements with four countries

The Minority in Parliament has raised concerns over government’s intention to approve Double Taxation Agreements with the Czech Republic, Morocco, Mauritius and Singapore which they claim were not in the interest of the country. According to the Minority, Ghana would not benefit from the deal since the level of investments… – Continue reading

Banks given 15 days to share foreigners’ data with FBR under OECD obligations

KARACHI: The Federal Board of Revenue (FBR) has given a 15-day timeline to banks and brokerages to furnish financial data of foreign customers as the country signed in an international convention for information exchange to curb tax evasion, officials said on Wednesday. The officials said FBR directed financial institutions, including… – Continue reading

Taiwan wealth management update

There have been a number of recent legal and regulatory changes in Taiwan that have impact from a wealth management perspective. Tax Rates Changes effective 2018 Effective 1 January 2018, the new tax rates for Taiwan are: Local foundation tax rule tightened Effective 1 January 2018, dividend for local foundations… – Continue reading

Nigeria, UAE agreement on stolen assets takes off

President Muhammadu Buhari’s anti-corruption drive moved a notch higher yesterday. Nigeria and the United Arab Emirates (UAE)’s agreement on recovery of assets and cash stashed away in UAE by Nigerians takes off next month. Besides, the collaboration among heads of anti-corruption agencies in Commonwealth (Africa) countries will be stepped up… – Continue reading

ANCA Renews Drive for U.S.-Armenia Double Tax Treaty

In the wake of Armenia’s peaceful, constitutional political transition – a move broadly welcomed among Washington, DC policymakers as marking a new chapter in U.S.-Armenia relations – the Armenian National Committee of America (ANCA) has renewed its longstanding drive for a U.S.-Armenia Double Tax Treaty, a good-governance accord needed to… – Continue reading

Analysis: The double taxation treaty (DTT), a case of Nigeria and Singapore

President Muhammadu Buhari move to halt tax evasion signs an agreement with Singapore President Muhammadu Buhari, on Monday 26 March 2018, signed the instrument of ratification of agreement with Singapore against double taxation and fiscal evasion. The President’s assent is pursuant to the approval of the double taxation treaty (DTT)… – Continue reading

Zimbabwe, Qatar to pursue investment protection, taxation agreements

HARARE, May 7 (Xinhua) — Zimbabwe and Qatar on Monday agreed to expeditiously negotiate and conclude agreements that protect future investments and avoid double taxation, Finance and Economic Development Minister Patrick Chinamasa has said. Addressing journalists in Doha, Qatar, after the first meeting between Zimbabwean President Emmerson Mnangagwa and Amir… – Continue reading

Delhi High Court refuses to stop Vodafone’s UK arbitration

MUMBAI, MAY 7 The Delhi High Court has refused to stop the arbitration filed by Vodafone Plc in the UK against the ₹22,000-crore tax claim by the Indian tax department. The court said that the Centre can approach the UK arbitration tribunal under the India-United Kingdom Bilateral Investment Protection Agreement… – Continue reading

Malta Ratifies BEPS Convention

Malta has become the latest country to ratify the OECD’s multilateral convention to counter base erosion and profit shifting (BEPS). A notice was published in Legal Notice 142 of 2018 in the territory’s Official Gazette. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20… – Continue reading

LUX-FRANCE DTT: CLARIFY BEFORE YOU RATIFY

Alfi speaks out on the double taxation treaty signed between Luxembourg and France on 20 March 2018. Although it appreciates that it is the product of bilateral negotiation, it calls for more clarity before it is ratified. The Association of the Luxembourg Funds Industry (Alfi) has added its voice to… – Continue reading

No Income Tax on Lottery Prize since Tax was already paid under Sikkim State Income Tax Rules: SC [Read Judgment]

In Mahaveer Kumar Jain vs. Commissioner of Income Tax, the Supreme Court held that the income earned by the assessee from lottery prize cannot be subjected to tax under Income Tax Act, 1961 when the same tax was already paid under Sikkim State Income Tax Rules, 1948. The appellant had… – Continue reading

Accidental Americans’ fight to stop double taxation

PARIS — Tom Wallis was born here and has spent his entire life in France, but it turns out that the 40-year-old entrepreneur from Grenoble owes tens of thousands of dollars in taxes to the United States. Wallis’ mother was French, but he holds U.S. citizenship through his American father…. – Continue reading

Switzerland and Cameroon to find a solution to the double taxation of companies operating in both countries

(Business in Cameroon) – During the inauguration of Nestlé Cameroon’s new production unit on April 12, 2018, in Douala, Pietro Lazerri, the Swiss ambassador to Cameroon informed that his country and Cameroon would initiate discussions to find a solution to the double taxation of companies operating in both countries. The… – Continue reading

UK Revisits Proposed BEPS Changes To Its Double Tax Treaties

The UK tax agency, HM Revenue and Customs, on April 16, 2018, released proposed changes to the list of amendments it intends to make to its bilateral double tax avoidance agreements through the OECD’s base erosion and profit shifting multilateral instrument. The new document – Proposed changes to the provisional… – Continue reading

Macao, Vietnam sign agreement to avoid double taxation, prevent tax evasion

MACAO, April 16 (Xinhua) — An agreement was signed between China’s Macao Special Administrative Region (SAR) and Vietnam to avoid double taxation as well as prevent tax evasion, according to a press release by the Macao SAR’s financial service department on Monday. The agreement, signed by Macao SAR Secretary for… – Continue reading

GDT reminds firms to mind US tax act FATCA

The General Department of Taxation on Friday issued a statement reminding Cambodian financial institutions to comply with the reporting requirements of the US’s Foreign Account Tax Compliance Act (FATCA). Cambodia and the US have signed an agreement to enforce FATCA, which mandates that financial institutions holding certain amounts of money… – Continue reading

Seychelles Needs To Redouble BEPS Efforts: UN Expert

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in… – Continue reading

Australia Provides Update On International Tax Enforcement

In comments to the TPMinds International Conference in late March, Deputy Commissioner Mark Konza outlined the Australia Taxation Office’s priorities in the area of international tax enforcement, with an especial focus to be placed on the energy and resources sector and pharmaceutical industry. His comments, published by the ATO on… – Continue reading

Cambodia, Vietnam ink double taxation agreement

Cambodia has signed a double taxation agreement with Vietnam that protects each country’s nationals from dual taxation, according to a news release from the General Department of Taxation released on Tuesday. The agreement was signed on Saturday on the sidelines of the Greater Mekong Subregion Summit held in Hanoi. Chou… – Continue reading

Qc Backs Income Taxes To Ease ‘Rich/Poor Divide’

AN outspoken QC is backing the introduction of corporate and personal income taxes as a way to reduce “the gulf between rich and poor” in the Bahamas. Fred Smith QC, the Callenders & Co attorney and partner, has added his voice to those urging the Government to use the European… – Continue reading

Court classifies medical firm tax planning as evasion

Tax authorities reviewed a case in which a doctor worked at a limited partnership firm and was paid via a limited liability company. The court described the arrangements as tax evasion. Many professionals would prefer to pay taxes on capital income because the tax burden is lighter than on earned… – Continue reading

TAX TALK: LUX-FRANCE TREATY CREATES UNCERTAINTY

On the occasion of the signing of the new double taxation treaty (DTT) between Luxembourg and France on 20 March 2018, the grand duchy’s finance minister, Pierre Gramegna, commented in a government press release that the new DTT is, “…an innovative instrument that will benefit both citizens and business in… – Continue reading

Kazakhstan ratifies double taxation protocol with Belarus

ASTANA, 29 March (BelTA-Kazinform) – The Senate (upper house) of the Parliament of Kazakhstan passed the law on the ratification of the protocol between the Government of the Republic of Kazakhstan and the Government of the Republic of Belarus on amendments and additions to the agreement on the avoidance of… – Continue reading

India Adds BEPS Provisions To Qatar Tax Treaty

India has approved amendments to its double tax agreement with Qatar. The amendments update the information exchange provisions between the two countries in line with current international standards. A new Limitation on Benefits (LOB) provision has been introduced, which is designed to prevent “treaty shopping” (whereby companies or transactions are… – Continue reading

Multinational tax avoidance plan extended

The federal government wants to block multinational companies using trusts and partnerships to escape paying tax in Australia. Assistant to the Treasurer Michael Sukkar introduced legislation to parliament on Wednesday that would bring artificial or contrived arrangements involving trusts and partnerships under the multinational tax avoidance laws introduced in 2016…. – Continue reading

Australian Tax Office Seeks Input On Cryptocurrency Tax Obligations

The Australian Tax Office (ATO) has launched a community consultation to seek feedback on practical compliance issues arising from complying with taxation obligations in relation to cryptocurrency transactions. On March 13, the ATO updated its web guidance tax treatment of cryptocurrencies to address some of the common enquiries in relation… – Continue reading

Buhari signs double taxation agreement with Singapore

President Muhammadu Buhari on Monday signed two agreements with two countries following the approval of the Federal Executive Council (FEC). The agreements, according to a statement issued by the Special Adviser on Media and Publicity to the President, Femi Adesina, include the instrument for ratification of agreement between Nigeria and… – Continue reading

Professional Fee paid by Deloitte India to Its US and Singapore Entities Not Taxable in India, No TDS: ITAT [Read Order]

Granting tax relief to Deloitte India, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) held that the provisions relating to Tax deduction at Source (TDS) are not applicable to the professional fee paid by them to its Group Entities in US and Singapore. The division bench of the… – Continue reading

BEPS Multilateral Instrument To Enter Into Force

The OECD has announced that its multilateral convention to implement tax treaty-related measures to counter base erosion and profit shifting will enter into force on July 1, 2018. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20 Finance Ministers and Central Bank Governors, will… – Continue reading

Cyprus and UK sign updated Convention on the Elimination of Double Taxation

The Republic of Cyprus and the Government of the United Kingdom of Great Britain and Northern Ireland, signed on March 22, in Nicosia, an updated Convention on the Elimination of Double Taxation with respect to Taxes on Income and on Capital Earnings and the Prevention of Tax Evasion of tax… – Continue reading

Ukraine and Qatar sign agreement on avoiding double taxation

Foreign Minister of Ukraine Pavlo Klimkin and Finance Minister of Qatar Ali Shareef Al-Emadi have signed an agreement on avoiding double taxation and preventing income tax evasion between the government of Ukraine and Qatar. According to a Thursday posting on the website of the Finance Ministry of Ukraine, avoiding double… – Continue reading

Cyprus, UK sign updated double taxation treaty

Cyprus and the UK on Thursday signed an updated agreement on double taxation avoidance on income and capital, which will contribute to further develop commercial and financial relations between the two countries. The agreement, signed in Nicosia by Finance Minister Harris Georgiades and British High Commissioner Matthew Kidd, is based… – Continue reading

Govt. revises Agreement between India and Qatar for avoidance of double taxation

The Union Cabinet chaired by Prime Minister Narendra Modi today gave its approval for revision of the Agreement between India and Qatar for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income. The existing Double Taxation Avoidance Agreement (DTAA) with Qatar… – Continue reading

Malta Backs EU Crackdown On Aggressive Tax Planning

Malta has reiterated its commitment to fighting aggressive tax planning, joining other EU member states who have unanimously agreed to amend the EU’s tax information sharing law, the Directive on Administrative Cooperation. The amendments to the Directive, which were agreed last week by EU finance ministers, will require intermediaries, such… – Continue reading

Pakatan’s SST Will Not Relieve People’s Burden, Senseless For The Future

Pakatan Harapan had unveiled an election manifesto earlier this month stating that they will restore the Sales and Service Tax (SST) after abolishing the Goods and Services Tax (GST) within the first 100 days of its administration. While the Prime Minister had pointed out earlier that Malaysia will only be… – Continue reading

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying… – Continue reading

US And Liechtenstein To Negotiate Double Tax Treaty

The governments of Liechtenstein and the United States have recently discussed the possibility of beginning negotiations for a bilateral double tax avoidance treaty. According to a Liechtenstein Government statement issued on March 15, “the fight against financial and tax crime” was the main focus of recent talks between Liechtenstein Foreign… – Continue reading