Category: Tax treaties

Labour and unions demand action on temp agencies’ tax avoidance

Opposition vows to shut down scheme that uses ‘contrived’ financial arrangements to slash national insurance bills Labour and trade unions have called on the government to take action after a Guardian investigation found that an aggressive tax avoidance scheme used by temporary recruitment agencies is depriving the taxpayer of “hundreds… – Continue reading

EU Parliament May Lose Right to Veto Public Tax Reporting

The European Parliament risks losing the right to veto plans to make multinational companies publish tax and profit details for the countries in which they operate, according to the European Union’s legal advisers. The Council of Ministers’ legal service insisted in its opinion, seen by Bloomberg BNA, that the European… – Continue reading

To Boost Trade, A Bilateral Tax Treaty Between India And The UK May Be In The Offing

Following British Prime Minister Theresa May’s visit to India last week, Patricia Hewitt, chair of the UK-India Business Council, said that Britain is looking to re-balance its commercial links with countries like India post-Brexit. She suggested that the two governments should look at a bilateral tax treaty to boost trade…. – Continue reading

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs… – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

Hong Kong Pushes For DTA, Info Exchange With Australia

In Canberra, Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, expressed his wish to quickly start negotiations on a comprehensive double taxation agreement (CDTA) with Australia. During his meetings with Australia’s Treasurer, Scott Morrison, and the Minister for Revenue and Financial Services, Kelly O’Dwyer, Chan pointed… – Continue reading

Finnish Expats In Portugal Face Higher Taxes

Finland will have “more possibilities” to tax Finnish pensioners living in Portugal under a recently revised bilateral double taxation avoidance treaty, the Finnish Government has said. The new agreement was signed on November 7 by Portuguese Finance minister Mario Centano and his Finnish counterpart Petteri Orpo, who declared himself “very… – Continue reading

New Zealand Planning More BEPS Measures

New Zealand’s tax agency has set out the international tax initiatives it intends to pursue, in particular in response to the OECD’s base erosion and profit shifting plan. It said it will undertake further work on a package of BEPS initiatives, which will include hybrid mismatch rules to prevent companies… – Continue reading

Multinationals still able to use ‘double Irish’ tax arrangement after 2020

Multinational companies will still be able to use the controversial “double Irish” tax arrangement after the final end date of 2020, Sinn Féin MEP Matt Carthy has said. A number of tax experts have confirmed this is the case, though they have disputed whether the terms of which they will… – Continue reading

Nearly 100 Countries Poised to Adopt Multilateral Treaty

Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading

UK, Colombia In Double Tax Deal

The UK and Colombia signed a double tax agreement (DTA) on November 2, which is intended to support trade and investment by capping withholding tax on cross-border income. The agreement was signed by the Financial Secretary to the Treasury, Jane Ellison, and the Colombian Finance Minister, Mauricio Cardenas, during President… – Continue reading

Israel to Tax Earnings from International Money Transfers

A multinational company based in a jurisdiction that has no tax treaty with Israel must pay Israeli taxes on its Israel-related earnings from international money transfer services, the Israel Tax Authority determined. The ruling is set to apply to the growing number of financial service firms entering the Israeli market,… – Continue reading

UAE, Argentina sign deal on double taxation

The UAE has signed an agreement on the avoidance of double taxation with Argentina with the aim of boosting expanding joint economic partnerships. The agreement was signed by Obaid Humaid Al Tayer, Minister of State for Financial Affairs, and visiting Argentina’s Vice President Gabriela Michetti, in the presence of Fernando… – Continue reading

EU Countries Block Use of Rates as Tax Haven Criteria

A “number” of European Union countries are blocking a push to include zero corporate tax rates as criteria for the bloc’s tax haven blacklist, according to Slovakia, which holds the rotating EU presidency. EU members have been unable to reach an agreement on cracking down on offshore structures aimed at… – Continue reading

It will promote greater economic cooperation between Latvia and Switzerland

Wednesday, 2 November, Finance Minister Dana Reizniece-oak and Swiss Ambassador Latvian Marcus Niklauss Paul Dutli ( Markus Niklaus Paul Dutly ) signed the Latvian Republic and the Government of the Swiss Federal Council Protocol amending the two parties on 31 January 2002 concluded the Convention for the Avoidance double taxation… – Continue reading

PH eyes tax treaties with Asean peers

The Philippines is eyeing to seal tax treaties with all nine other Asean member-states, according to the Bureau of Internal Revenue (BIR). The country already has effective double taxation agreements (DTAs) with Indonesia, Malaysia, Singapore, Thailand and Vietnam, BIR Assistant Commissioner Marissa O. Cabreros noted in a presentation at last… – Continue reading

UAE’s tax regime: The need of the hour

Creating of a Federal Tax Authority is the logical next step in seeing it through Within the span of month the UAE took two bold steps with the aim to develop a proper legislative and legal structure for the post-oil period. The first was to launch the Bankruptcy Law and… – Continue reading

India-Japan amended tax treaty comes into force

The amended bilateral tax treaty between India and Japan, which provides for strengthened exchange of information to help reduce tax evasion, has come into force from October 29. The agreement to amend the 27-year old Double Taxation Avoidance Agreement (DTAA) was signed when Japanese Prime Minister Shinzo Abe visited India… – Continue reading

OECD Reviewing U.S. Handling of Double-Tax Cases

The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading

FBR okays team to execute AEOI project

After getting approval from Finance Minister Ishaq Dar on the pilot project of automatic exchange of information (AEOI), the Federal Board of Revenue (FBR) has approved a team to execute the project with the Organisation for Economic Cooperation and Development OECD Member countries. According to a notification issued by the… – Continue reading

McDonald’s UK pays £123m in royalties to Luxembourg

The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading

Hong Kong Consults On BEPS Implementation

On October 26, Hong Kong’s Government launched a public consultation on the implementation of base erosion and profit shifting (BEPS) measures proposed by the OECD. “Hong Kong is supportive of international efforts to promote tax transparency and combat tax evasion,” said Secretary for Financial Services and the Treasury K C… – Continue reading

India-Korea DTAA notified, capital gains to be taxed at source

India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading

With 42% increase in trade, India-NZ agree to amend Double Taxation Agreement

India and New Zealand also vowed to press for successful negotiations of the Regional Comprehensive Economic Partnership (RCEP). India and New Zealand decided to amend the bilateral tax treaty and expressed commitment to work towards a comprehensive free trade agreement with a view to boost economic ties on Wednesday. The… – Continue reading

Panama to join international tax convention on Thursday: OECD

Panama will take a big step towards ending its status as an offshore tax haven on Thursday by signing a multilateral convention to share foreign taxpayer details with other governments, the OECD‘s head of tax said. Panama’s role as a major offshore tax haven came into the public spotlight earlier… – Continue reading

Armenia eliminates double taxation of property and income with Serbia and Slovakia

The Armenian Parliament has ratified today two agreements to avoid double taxation and prevent tax evasion with respect to taxes on property and income with Serbia and Slovakia. According to Deputy Minister of Finance Armen Hayrapetyan, the document on the mutual avoidance of double taxation on property and income with… – Continue reading

Hong Kong to commence automatic exchange of financial account information in tax matters with Japan and UK in 2018

Hong Kong has signed agreements with Japan and the United Kingdom with a view to commencing automatic exchange of financial account information in tax matters (AEOI) with these two tax jurisdictions in 2018, a Government spokesman said today (October 26). In September 2014, Hong Kong indicated its support for the… – Continue reading

Pakistan to seek offshore companies information from nine tax havens

Pakistan’s authorities are making efforts to seek information about tax details of 270 offshore companies from nine known tax havens around the globe where 444 individuals have invested billions of dollars, and, finally, their names appeared through PanamaLeaks, The News has learnt. The cases of 444 individuals involving nine jurisdictions… – Continue reading

Pakistan signs PTA with Mauritius

Governments of Pakistan and Mauritius on Friday signed a number of trade deals which included the Preferential Trade Agreement (PTA) – an agreement on avoidance of double taxation – which have a great potential for enhancing their bilateral trade. These agreements were signed during discussions held at the Mauritius Board… – Continue reading

OECD sets timeline for country profiles for cross-border tax disputes

The OECD has set the minimum standards it requires from countries submitting Mutual Agreement Procedure (MAP) profiles, with only 41 countries currently having a completed profile, which will be used as a tool for resolving cross-border tax disputes The MAP falls under Action 14 on the Base Erosion and Profit… – Continue reading

Japan, Austria Agree MAP Arbitration

The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading

Chinese dual tax burden relieved

An extensive tax treaty that would shield Chinese businesses operating in the Kingdom from double taxation, and vice versa, has been drafted and is expected to be approved imminently, according to a senior Cambodian tax official. Experts said yesterday the double taxation agreement (DTA) would create a clear legal framework… – Continue reading

China Issues More Rigorous Advance Pricing Agreement Rules

China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading

Turkmenistan ratifies deal with Germany to avoid double taxation

Turkmenistan in a bid to expand its bilateral ties with Germany in the trade sphere ratified an agreement on the avoidance of double taxation with respect to income and property taxes, the Turkmen government reported. The document signed with Germany was approved at the regular meeting of Parliament this week…. – Continue reading

Iran, Luxemburg agree on mutual investment, double taxation avoidance

The decision was made during a meeting between Iranian Finance and Economic Affairs Minister Ali Tayyenbia and the visiting Luxembourg Economy Minister Etienne Schneider in Tehran on Monday, IRNA reported. As reported, the Luxembourger minister also visited Central Bank of Iran Governor Valiollah Seif on Tuesday. Expressing satisfaction over the… – Continue reading

Gov’t, Chile agree deal to end ‘double taxation’

Argentina and Chile yesterday announced the implementation of a long-awaited agreement to eliminate double taxation for residents of both countries in order to encourage investment and prevent tax evasion. Chile’s Foreign Minister Heraldo Muñoz, Public Works Minister Alberto Undurraga, and Finance Minister Rodrigo Valdés met with Argentina’s Finance Minister Alfonso… – Continue reading

Ukraine and Luxembourg sign a Protocol modifying their double tax treaty

On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading

IRS, Mexico Reach Tax Deal For Contract Manufacturers

U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading

Georgia-Kyrgyzstan sign agreement on double taxation

Georgia and Kyrgyzstan are increasing economic cooperation by signing an agreement on avoidance of double taxation. The deal was signed today in Georgia’s capital Tbilisi and will prevent people or businesses working between the two countries from evading income and capital taxes. Double taxation is the levying of tax by… – Continue reading

BHP Billiton has evaded taxes for more than a decade, says Wayne Swan

Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading

Saudi joins talks on VAT, selective tax in GCC states

The Saudi Council of Ministers has authorized minister of finance or his deputy to discuss two draft uniform agreements on value added tax (VAT) and selective tax for Gulf Cooperation Council (GCC) states. The agreements shall be discussed within the framework of the GCC financial and economic committee, and sign… – Continue reading

Singapore wants to delay revision of tax treaty with India

Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into… – Continue reading

Finnish Royalties To Estonia No Longer Taxed

The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading