Category: Tax treaties

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

Bangladesh, Morocco sign deal on avoidance of double taxation

In a meeting, both sides agreed to strengthen bilateral cooperation in the areas of economic development, trade and investment, agriculture and tourism cooperation Bangladesh and Morocco have signed an agreement on avoidance of double taxation and a protocol on Foreign Office Consultations. The two instruments were signed by Foreign Minister… – Continue reading

Dutch Cabinet Approves Anti-Evasion Measures

The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – 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

OECD Urges Countries Not To Go It Alone On Digital Tax

The problems posed by the digitalization of the economy should be addressed collectively and any interim measures taken by countries unilaterally should be “as little damaging as possible,” the OECD’s Director of Taxation has said. Pascal Saint-Amans told the Irish Independent that to “find a long-term solution, you need to… – 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

AGREEMENT TO AVOID DOUBLE TAXATION ON MACAU AND TAIWAN AVIATION INDUSTRY

The agreement to avoid double taxation on the aviation industry across Macau and Taiwan came into effect in the second week of February. The Chief Executive signed a notice, which was published in the government’s Official Gazette, notifying the implementation of the memorandum. The notice remarks on how the implementation… – Continue reading

China’s Anti-tax Avoidance Rules

The general anti-avoidance rule was first introduced in China under the 2008 CIT Law. It empowers Chinese tax authorities to make reasonable adjustments where an enterprise implements an arrangement without reasonable business purposes in order to reduce its taxable income or profit. According to the CIT Law’s Implementation Guidelines, “an… – 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

China Sets Out How To Determine Beneficial Owner For Treaties

On February 3, 2018, China’s State Administration of Taxation set out new rules on the disallowance of tax treaty benefits where an entity fails to demonstrate it is the beneficial owner of Chinese assets from which passive income is derived. A beneficial ownership requirement is introduced in treaties to prevent… – Continue reading

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime…. – Continue reading

India Concludes First US Bilateral Advance Pricing Agreement

The Indian Central Board of Direct Taxes on February 7 announced that it entered into its first ever bilateral advance pricing agreement with a US firm, in cooperation with authorities in the US. In total, during January 2018, the CBDT entered into five unilateral APAs and two bilateral APAs. CBDT… – 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

Israel set to adjust tax policies to counter Trump reform, tax chief says

Also, multinational companies with a physical presence in Israel will soon get their first tax bill Israel will need to amend its corporate tax policies to counter the effects of US President Donald Trump’s tax reform, the head of Israel’s Tax Authority head acknowledged — but only slightly. “There will… – 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

Barbados, Jamaica Sign New International Tax Treaty

PARIS, France– Ministers and high-level officials from six countries, including two in the Caribbean, have signed the BEPS Multilateral Convention, the first multilateral treaty of its kind. The Convention will enable governments to swiftly update their networks of existing tax treaties and further reduce opportunities for tax avoidance. Barbados, Jamaica,… – 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

European Union removes UAE from tax haven blacklist

UAE was confident of swift removal from the tax haven list in 2018. The UAE, along with seven other countries, has been removed from the European Union’s list of Uncooperative Tax Havens as the country further enhanced its transparency in tax procedures. As a mark of strengthening ties with EU… – Continue reading

Jamaica, Italy sign elimination of double taxation agreement

KINGSTON, Jamaica (JIS) — The Government of Jamaica has signed an agreement with the Republic of Italy for the elimination of double taxation with respect to taxes on income and for the prevention of tax evasion and avoidance. The signing took place at the Ministry of Finance and Public Service’s… – Continue reading

Govt to announce amnesty for undeclared foreign assets ahead of OECD’s treaty

KARACHI: Government on Saturday said it may roll out an amnesty to allow offshore bank account holders to declare their wealth against nominal tax rates ahead of the implementation of OECD’s treaty to exchange financial details with foreign countries in September. Miftah Ismail, adviser to the Prime Minister for finance,… – Continue reading

Malaysia Updates Mutual Agreement Procedure Guidelines

Malaysia’s Inland Revenue Board (IRB) on January 11, 2018, released guidelines on applying for the resolution of double tax cases through the Mutual Agreement Procedure. The MAP Guidelines have been updated to incorporate the recommendations of the OECD BEPS Action 14 report on making dispute resolution mechanisms more effective. The… – Continue reading

Transfer Pricing Dispute Resolutions in India: New Relaxations

The Income Tax Department recently released a clarification stating that it would accept requests for mutual agreement procedures (MAPs) and bilateral advance pricing agreements (BAPAs) in transfer pricing disputes with all countries regardless of the existence of specific provisions in the Double Taxation Avoidance Agreements (DTAAs). A 2012 survey by… – Continue reading

Taxation agreement with Singapore in effect

The double tax avoidance agreement (DTA) between Cambodia and Singapore came into effect this month, helping clarify taxation rights on all forms of income arising from cross-border business activities, while minimising double taxation. On January 1 the Inland Revenue Authority of Singapore (IRAS) issued an announcement stating that the DTA… – Continue reading

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended… – 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

US tax reform breaks global rules, EU says

European finance ministers are worried. They say the United States’ big tax reform bill contains measures that would unfairly disadvantage European business and contravene global fair-taxation rules. Are they right? Last week, the finance ministers of Europe’s five biggest economies — Germany, France, the UK, Spain and Italy — wrote… – 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

Bahamas Faces Major Tax, Exchange Control Shake-Up

The Bahamas may have to completely overhaul its corporate and taxation structure to escape European Union/OECD ‘blacklisting’ threats, the Attorney General revealed yesterday. Carl Bethel QC told Tribune Business that the Government was “looking very carefully” at whether compliance with European (EU) demands will require this nation to eliminate the… – Continue reading

Bermuda Premier signs tax agreement with US, visits Jamaica

HAMILTON, Bermuda (CMC) — Bermuda has signed a new tax agreement with the United States that premier David Burt says demonstrates the island’s continued commitment to transparency. Burt, who left here over the weekend for Jamaica, said the Country by Country Competent Authority Agreement signified that the PLP government had… – Continue reading

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice… – Continue reading

AmCham EU Speaks Out Against EU Digital Tax Proposals

The American Chamber of Commerce in the European Union has criticized the proposals put forward in the European Commission’s recent consultation on options for new tax rules or a new tax on digital firms. The aim of that consultation is to help the Commission to define an approach to the… – Continue reading

Pakistan, Hong Kong ratify treaty to avoid double taxation

ISLAMABAD: Pakistan and Hong Kong on Monday ratified a treaty signed early this year to stave off double taxation on incomes of their individuals and companies. “Pakistan and Hong Kong SAR (special administrative region) have ratified the avoidance of double taxation and prevention of fiscal evasion with respect to taxes… – Continue reading

Belarus-Hong Kong double taxation agreement comes into force

MINSK, 4 December (BelTA) – The double taxation agreement between Belarus and Hong Kong, a special administrative region of China, has come into effect, BelTA learned from the Belarusian Embassy in Beijing. “After Belarus and China went through the necessary domestic procedures, the Belarus-Hong Kong agreement on the avoidance of… – 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

OECD statistics show 20% increase in outstanding tax treaty disputes involving UK

The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading

Barbados To Sign OECD Pact To Revise Its DTAs In January

Barbados says it expects to sign the new OECD BEPS Multilateral Instrument at the end of January 2018 to introduce changes to its tax treaty network to prevent base erosion and profit shifting. The “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS)”… – Continue reading

Ten important Canadian Tax compliance considerations for new Canadians

The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on… – 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