Category: Tax treaties

European Commission publishes anti-avoidance package

On 28 January 2016, and in response to the OECD’s Base Erosion and Profit Shifting (BEPS) project, the European Commission published a package of anti-avoidance measures as part of its ongoing plans to ultimately introduce a common consolidated corporate tax base (CCCTB). The package comprises: a draft anti-avoidance Directive, with… – Continue reading

UAE – Jersey trade relations: from a tax haven to taxonomy

As with any offshore financial centre, secrecy has been synonymous with the Channel Islands of Jersey. But the reason for the strong relations between the self-governing British dependency and the United Arab Emirates – still not known to many – is not confidentiality alone. It has not been so long… – Continue reading

Equalization levy resistance shows up BEPS’ challenges

The Internet and Mobile Association of India’s (IAMAI’s) pushback against the equalization levy on e-commerce transactions introduced in the union budget shows up the difficulty revenue authorities will have when they try to protect their tax base. The last word on this subject hasn’t been said and the original budget… – Continue reading

Key features of new Thai-Indian DTA

THE DOUBLE taxation treaty (DTA) between India and Thailand has been successfully renegotiated and agreed to by both states and will come into force in January next year. The key highlights include a reduction of withholding tax on dividends, interest and royalties. Article 10 reduces the dividend withholding tax to… – Continue reading

Tax Notes: Protocol Amending RP – New Zealand Tax Treaty

THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading

Ireland’s tax treaties costing poorer countries, claims NGO

Ireland’s tax treaties with poorer countries are some of the most restrictive in the world, limiting the taxing rights of those countries, an international NGO has claimed. Action Aid said that globally, tax treaties cost developing countries billions every year. In a report released yesterday, the body said it has… – Continue reading

In Absence of GST, Service Tax Lawsuits on Rise: Experts

Service tax litigations have risen substantially in recent years and that may be because of the absence of a pan-India Goods and Services Tax (GST) regime that can potentially remove several ambiguities around indirect taxation, experts maintain. A total of 75,314 litigations were pending with the Department of Revenue, the… – Continue reading

CBDT proposes foreign tax credit rules, to help corporates

To provide relief to corporates having income abroad, the tax department today proposed simplified ‘Foreign Tax Credit’ rules allowing companies to claim credit for taxes paid overseas. The Central Board of Direct Taxes (CBDT) in its draft FTC rules said tax credit will be available to entities paying taxes in… – Continue reading

Hong Kong, Latvia Sign DTA

On April 13 in Riga, Hong Kong’s Secretary for Financial Services and the Treasury K C Chan signed a comprehensive double taxation agreement between Hong Kong and Latvia. “This is the 35th CDTA that Hong Kong has signed with its trading partners and it signifies the Government’s ongoing efforts to… – Continue reading

Ethiopia’s parliament ratifies double taxation avoidance with four countries

Ethiopia’s House of People’s Representatives (National Parliament) in its regular meeting on Friday ratified a bill to avoid double taxation with Saudi Arabia, Portugal, and Democratic People’s Republic of Korea based on the agreement the nation earlier signed with those countries. The elimination of double taxation helps to increase investment… – Continue reading

EU tells companies to reveal how much tax they pay by country in latest avoidance crackdown

Businesses will be forced to declare how much they make in each European country and in certain tax havens as part of an attempt to curb schemes that shift profits out of the reach of tax collectors. The plan to introduce country-by-country reporting in Europe is the latest global curb… – Continue reading

India, Maldives sign pact to curb tax evasion

India and Maldives today signed two agreements for exchange of information with respect to taxes, and for avoidance of double taxation of income derived from international air transport. The agreements were signed during the visit of President of Maldives Abdulla Yameen Abdul Gayoom to New Delhi. Gayoom is on a… – Continue reading

No more double taxation for Zimbos working in SA

Government has gazetted a Statutory Instrument (SI) to stop double taxation of Zimbabweans living and working in South Africa or South Africans working in Zimbabwe. The provision was gazetted last Friday. Part of the SI reads: “Subject to the provisions of article 16, 18 and 19, salaries, wages and other… – Continue reading

EU wants companies to disclose where they pay taxes

The European Union’s executive wants thousands of multinationals to disclose in what member states they make money and pay taxes, an effort to close loopholes and crack down on the use of tax havens. Reacting to public anger over tax avoidance by some of the globe’s best-known companies and by… – Continue reading

The problem of secretive tax havens

Panama is a tax haven, but Mauritius is one with which India has a comprehensive double tax treaty. This complicates matters more. In popular Indian imagination, a tax haven is generally associated with Switzerland and its numbered bank accounts. But tax havens are numerous, have grown in importance, and are… – Continue reading

Adventures in tax avoidance: Canada’s deep offshore tax haven connections

Much of the activity is legal, but it siphons away billions in tax revenue from government coffers The massive Panama Papers data leak shines a light not only on the dirty money being shuffled through tax havens, but also on the legal and common use of offshore accounts to significantly… – Continue reading

Commission to extend state aid investigation into more transfer pricing agreements

The European Commission is looking into advance pricing agreements (APAs) given to financing companies and other businesses to see if they constitute illegal state aid, the MNE Tax news site has reported EU competition commissioner Margrethe Vestager told the European Parliament’s TAXE 2 committee that her office has reviewed 1,000… – Continue reading

Cyprus-India build on ties

Lobby groups and business associations from Cyprus and India are working to build trade relations between the two countries with an eye to a new double taxation agreement that is being negotiated. The two sides see mutual benefits to their cooperation. The Indian High Commissioner Ravi Bangar said in an… – Continue reading

African nations urged to rethink incentives

African governments should embrace meaningful bilateral investments agreements to foster sustainable economic growth on the continent. The call follows a report by the UN Economic Commission for Africa (ECA) on investment policies and bilateral investment treaties by Africa, indicating a huge gap between most of signed treaties and their actual… – Continue reading

Tax incentives for small and mid-size companies

Most small and mid-sized companies can qualify for tax incentives if they claim to be developing, engineering, designing, modifying, researching or evaluating new products or product alternatives. Among those incentives is the research and development tax credit. The R&D credit is a way for companies to access cash and reduce… – Continue reading

Li: Tax reform to boost vitality of real economy

Premier Li Keqiang’s message to the country’s tax and financial authorities is crystal clear: The ongoing landmark tax reform must reduce burdens on all industries. One month before the May 1 deadline of a sweeping reform that seeks to replace China’s decadeslong business tax with a value-added tax, Li visited… – Continue reading

No Agreement On Australian State Tax Devolution

The leaders of Australia’s federal, state, and territory governments have failed to reach an agreement on a proposal to enable the states to levy income tax. The Council of Australian Governments (COAG) met on April 1. Ahead of the meeting, Federal Prime Minister Malcolm Turnbull had proposed that the federal… – Continue reading

The missing billions of multinational tax

It’s easy to stoke outrage at multinationals’ low taxes but harder to do something about it. According to the Organisation for Economic Co-operation and Development (OECD) – the so-called rich-countries club – tax avoidance by multinational companies is worth US$100-240 billion a year. That’s 4-10% of total global corporate income… – Continue reading

Avoidance of double taxation: Pakistan, Afghanistan complete first round of talk

Pakistan and Afghanistan on Wednesday completed first round of talks on the convention of avoidance of double taxation and prevention of fiscal evasion and mutually agreed on the initial draft of the convention. Sources told the Business Recorder on Wednesday that the negotiations between Afghan and Pakistani tax authorities were… – Continue reading

Canada Revenue Agency’s 2014-2015 annual report to Parliament: Focus on compliance measures

The Canada Revenue Agency (“CRA”) released its Annual Report to Parliament (“Report”), outlining the CRA’s performance and key statistics for 2014-2015. This article highlights some of the measures that the CRA has undertaken to combat non-compliance. During 2014-2015, the CRA assessed over $1.7 billion in additional taxes owing and identified… – Continue reading

KPMG: Moves to curb international tax dodges

Global international tax takes from multinational companies will almost certainly increase in the next 5-10 years as governments around the world look to level the taxation playing field. Commenting on the New Zealand Herald’s series examining ‘the tax gap’ – multinationals channelling earnings to lower tax regimes, disadvantaging some of… – Continue reading

Proposed Article 26: Swiss tax authorities bound to exchange information

The proposed Article 26 (exchange of information) of the convention on Avoidance of Double Taxation, being renegotiated between Pakistan and Switzerland, would bound the Swiss tax authorities to exchange all requested information, including confidential bank account information of Pakistanis maintaining Swiss accounts. Sources told Business Recorder here on Tuesday that… – Continue reading

US companies warn tax avoidance crackdown will hit earnings

Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading

Communications Tax: Experts Decry New Burden On Industry

In the last few weeks, a proposed communications service tax which sought to tax voice calls, SMS, MMS, Data and Pay TV used by subscribers has dominated the telecommunications space since it was presented as a bill before the national assembly with Nigerians describing it as another way of exploiting… – Continue reading

UAE, Finland sign agreement on exchange of information for tax purposes

ABU DHABI: The United Arab Emirates and the Republic of Finland have signed an agreement on the exchange of information for tax purposes between the two countries. The agreement was signed by Younis Haji Al Khoori, Undersecretary of the Ministry of Finance, MoF, and Riitta Swan, Ambassador of Finland to… – Continue reading

Georgia to avoid double taxation with South Korea

Georgia and South Korea are stepping up bilateral cooperation to avoid double taxation, boost investments and increase economic cooperation. Georgia’s Finance Minister Nodar Khaduri plans to visit South Korea and sign a cooperation agreement on avoidance of double taxation, prevention of evasion of income and capital taxes. Double taxation is… – Continue reading

Indonesia Seeks To Curb Use Of Tax Havens By Companies

Indonesia hopes its plans for a tax amnesty will dissuade companies from channelling profits through overseas tax havens and shopping around for the most advantageous tax treaties, its finance minister said on Wednesday. Bambang Brodjonegoro said he suspected Indonesian firms of setting up “special purpose vehicles” (SPVs) to benefit both… – Continue reading

Google tax’ looms large: Marketing spend might go up

Court cases likely over interpretation of the new levy proposed in the Budget for digital economy The government’s plan to expand the scope of equalisation levy proposed in the Union Budget, seeking to bring more transactions in the digital economy under the tax net, has left many e-commerce players fuming…. – Continue reading

New qualifying private placement exemption from UK withholding tax on interest: good news

The Finance Act 2015 introduced certain gateway conditions for the new exemption from UK withholding tax on interest payments for “qualifying private placements.” The Qualifying Private Placement Regulations 2015 setting out the detailed conditions for relief have now been made. While January 1, 2016 was appointed as the effective date,… – Continue reading

Follow Ireland’s Example on Corporate Tax to Stop Inversions

Ireland’s 12.5 percent corporate tax rate has encouraged several major U.S. companies like Medtronic, Pfizer, Johnson Controls, and Baxalta to move there in tax inversions in recent months, saving them billions of dollars of taxes and protecting themselves from international competition in the process. The U.S. corporate tax rate, on… – Continue reading

Singapore-UAE Tax Treaty Improved

The second Protocol to the double tax agreement between Singapore and the United Arab Emirates entered into force March 16, 2016, and will become effective from January 1, 2017, lowering withholding tax rates and amending permanent establishment rules. The protocol, which was signed in October 2014, revises the terms to… – Continue reading

Withholding tax on digital transactions

THE digital economy has increased opportunities for digital commerce companies to reap substantial sales from a country without establishing a taxable presence in that country. Existing permanent-establishment (PE) rules in both domestic laws and tax treaties require some type of physical presence before a PE is established in another country…. – Continue reading

Australian Government Seeks End to Double Taxation of Bitcoin

The Australian government has announced that it will back a legislative solution to tax concerns surrounding bitcoin as part of a broad policy statement on financial technology. Under current tax guidance in the country, bitcoin is considered a form of barter rather than a form of money. Australian businesses must… – Continue reading

Equalisation levy may not be the right move

The ways of doing business in a digital economy have evolved rapidly. Traditional tax norms, effective in addressing issues in a world before high-paced technological and e-commerce, are increasingly becoming outdated. Taxation of e-businesses has been a globally identified challenge with tax authorities acknowledging that corporates in this disruptive environment… – Continue reading