Tax experts have highlighted the increasing importance of substance in the fund management sector in view of the OECD’s base erosion and profit shifting (BEPS) project recommendations. The OECD’s recommendations, among other things, aim to realign taxation with economic substance and value creation, while preventing double taxation. Speaking at the… – Continue reading
THE Philippines and Mexico have discussed new ways to further improve trade and investment cooperation, and avoid incidents of double taxation, the Department of Finance (DoF) said. A recent meeting between Finance Secretary Carlos Dominguez 3rd and Mexican Ambassador to Manila Julio Camarena Villaseñor focused on Mexico’s concerns regarding a… – Continue reading
Russia will sign the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS), the Government announced on May 20. The Convention, developed by the OECD under Action 15 of the BEPS project, will transpose BEPS recommendations into over 2,000 tax treaties worldwide. According… – Continue reading
Japan and Iceland have agreed in principle to sign a convention aimed at eliminating international double taxation and preventing tax evasion, the Japanese Finance Ministry said Monday. The convention is hoping to boost mutual investment and encourage economic exchange, the ministry said. After signing, the convention is expected to come… – Continue reading
Kosovo and Switzerland signed on Friday an agreement regulating taxation of income and capital, which is beneficial for both countries, the Swiss federal government said. Under the agreement on double taxation dividends will be taxed at source at a maximum rate of 15%, while qualified participations – at no more… – Continue reading
Cyprus and the Caribbean island-state of Barbados signed a double tax avoidance and prevention of tax evasion treaty on Wednesday, the finance ministry said. “The agreed text will contribute to the development of commercial and financial ties between Cyprus and Barbados, as well as other countries,” the finance ministry said… – Continue reading
Malaysia uses both progressive and flat rates for personal income tax, depending on an individual’s duration and type of work in the country. As expatriates may fall into either tax category depending on their work, it is important to understand Malaysia’s basic tax structure. The Income Tax Act of 1967… – Continue reading
Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two… – Continue reading
Cyprus and San Marino have signed a double taxation avoidance agreement. The agreement, which further enhances the relations between the two states, was signed between the Ministers of Foreign Affairs of Cyprus and San Marino, Ioannis Kasoulides and Nicola Renzi, who held a tete – a – tete meeting before… – Continue reading
The Union Cabinet has given its approval for the signing of multilateral convention to implement tax treaty-related measures to prevent base erosion and profit shifting. A product of OECD/ G20 BEPS Project, this convention is aimed at tackling baseerosion and profit shifting through tax planning strategies that exploit gaps and… – Continue reading
The governments of Japan and Russia on April 28 announced they have agreed the text of a new double tax agreement that would replace the 1986 pact between Japan and the former USSR. In a statement following a visit by Japanese Prime Minister Shinzo Abe to Moscow, the Japanese Finance… – Continue reading
Malta denies claims A data leak has revealed information about 70,000 offshore companies in Malta, a German state minister claimed this morning. North Rhine-Westphalia finance minister Norbert Walter-Borjans said the data also included information about several German corporations and up to 2,000 German taxpayers. Tax authorities in the city of… – Continue reading
Luxembourg and Cyprus on Monday signed a bilateral convention for the elimination of double taxation. Luxembourg’s Finance Minister Pierre Gramegna was on a working visit in Nicosia and signed the convention with his Cypriot counterpart Harris Georgiades. Cyprus was the last EU member state not to have a tax convention… – Continue reading
Cyprus and Luxembourg, two of the EU`s financial centres, on Monday cautioned against the implementation of the proposed Common Consolidated Corporate Tax Base (CCTB) in the European Union. “Cyprus believes that we should be very cautious and very careful when it comes to corporate taxation,” Cypriot Finance Minister Harris Georgiades… – Continue reading
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading
It has been more than a year since the Australian government committed itself to remedying the nation’s double taxation scheme for cryptocurrencies. The delay in crafting a fix has left some observers wondering whether the issue had been set aside entirely. In a statement released this week, the government has… – Continue reading
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – Continue reading
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
Pakistan and Bulgaria on Wednesday signed the Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income (ADTA) after the conclusion of second round of negotiations in Islamabad. The ceremony was overseen by Federal Board of Revenue Chairman Dr Muhammad Irshad and Bulgaria… – Continue reading
The Federal Inland Revenue Service (FIRS) and the Economic and Financial Crimes Commission (EFCC) are putting a new breath to the fight against tax fraud and evasion in Nigeria, as the two agencies will soon launch an anti-tax fraud and evasion team. This collaboration, according to the FIRS Executive Chairman,… – Continue reading
In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an… – Continue reading
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
LUSAKA – Zambia and Malawi have resolved to harmonise trade barriers that affect trade between the two neighbours through the signing of the Double Taxation Avoidance Agreement (DTAA). The DTAA, also referred to as a Tax Treaty, is a bilateral economic agreement between the two nations that aims to avoid… – Continue reading
The United Arab Emirates (UAE) has signed an international tax agreement – Multilateral Convention on Mutual Administrative Assistance in Tax Matters(MAC), which is now seen as the ‘gold standard’ for co-operation in tax administration. With this move, UAE has become the 109th jurisdiction to join the most powerful multilateral treaty… – Continue reading
On April 13, 2017, the Ukrainian Parliament ratified its tax treaty with Malta, which provides for lower withholding tax rates on dividends, interest, and royalties. Under the deal, the withholding tax rate for dividends would be capped at 15 percent. A special rate of five percent would apply to dividends… – Continue reading
NEW DELHI, APRIL 19: The Union Cabinet on Wednesday approved the signing of the Protocol amending the Convention between India and Portugal for avoidance of Double Taxation. According to an official statement, the Protocol will also ensure prevention of fiscal evasion with respect to taxes on income. The statement said,… – Continue reading
(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading
Ghana and the Czech Republic have signed a Double Taxation Agreement. The Minister for Finance, Ken Ofori Atta, and the Czech Ambassador to Ghana, Margita Fuschova, signed on behalf of both countries. This agreement was signed after the two countries concluded negotiations for the Avoidance of Double Taxation and the… – Continue reading
The European Commission wants stricter guidelines for the “tax privileges’’ some European Union countries permit within special economic zones in their jurisdictions, to enhance economic development. The confidential proposal for the guidelines, seen by Bloomberg BNA, is currently under discussion within the EU’s Code of Conduct Group for Business Taxation,… – Continue reading
Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the… – Continue reading
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP… – Continue reading
Azerbaijan will sign agreements on elimination of double taxation with five more countries in the near future, Zaur Fetizade, head of Azerbaijani Taxes Ministry’s Department for International Cooperation and Tax Monitoring in Financial Institutions, said in his interview with the Vergiler (Taxes) newspaper. “We have already agreed on draft agreements… – Continue reading
China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the… – Continue reading
Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI), a Government spokesman said today (April 3). “We have been seeking to expand Hong Kong’s AEOI network with our tax treaty partners. The signing of agreements with Portugal… – Continue reading
The DTA clarifies the taxing rights on all forms of income flows arising from cross-border business activities and seeks to ensure such income is not taxed twice. The agreement provides that withholding taxes on dividends, interest, and royalties will generally not exceed seven percent. Withholding taxes on service fees will… – Continue reading
Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading
Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading
The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading
For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although… – Continue reading
The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of… – Continue reading
The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – Continue reading
On 14 March 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg “On Avoidance of Double Taxation and Prevention of Income and Capital Tax Evasion” (the “Convention”) and a protocol to it (the “Protocol”). As we informed… – Continue reading
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
ISLAMABAD: After Federal Minister for Finance Ishaq Dar took a ‘principled stand’, Pakistani and Swiss authorities are scheduled to ink a revised convention on avoidance of double taxation agreement today (Tuesday) here in the federal capital, enabling the Pakistani authorities to get information about dirty untaxed money of $200 billion… – Continue reading
The OECD and the International Monetary Fund have submitted to the Group of Twenty (G-20) nations a report on improving tax certainty for businesses. The report follows a global survey of more than 700 large, multinational businesses and a survey of 25 advanced nation tax administrations. The report highlights several… – Continue reading
MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning… – Continue reading
Hong Kong has signed agreements with six jurisdictions to automatically exchange financial account information in tax matters. The agreements expand Hong Kong’s Automatic Exchange Of Information (AEOI) network to include Belgium, Canada, Guernsey, Italy, Mexico, and the Netherlands. These countries join Japan, Korea, and the UK as “reportable jurisdictions” for… – Continue reading
Recently,Ghana signed an agreement with the government of Mauritius to ensure that its investors will not be taxed twice by the two countries. Apart from that there are other countries that have such an agreement with Ghana. Ghana uses the instrumentality of Double Taxation Agreements (DTA) to rationalize the tax… – Continue reading
The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be… – Continue reading
Ghana has signed an agreement with the government of Mauritius to ensure that its investors will not be taxed twice by the two countries and vice-versa. Known as the Double Taxation Avoidance agreement (DTA), the both Foreign Affairs ministers Shirley Ayorkor Botchwey and Mauritius counterpart Hon SeetanahLutchmeenaraidoo signed the agreement… – Continue reading
