Category: Tax treaties

Botswana, Malawi sign double taxation pact

Botswana and Malawi have signed an Agreement for the Avoidance of Double Taxation that aims to facilitate closer cooperation tax issues and allow for the exchange of information between their revenue authorities.Speaking at the signing ceremony on Wednesday, Botswana’s Finance Minister Kenneth Matambo said it was also pleasing that the… – Continue reading

Belarus, Kazakhstan update double taxation agreement

Belarus and Kazakhstan introduced amendments and additions to the intergovernmental double taxation agreement and thus updated the tax legislation, Belarus’ Taxes and Duties Minister Sergei Nalivaiko said after a ceremony to sign the protocol, BelTA has learned. The matter is about the protocol between the governments of Belarus and Kazakhstan… – Continue reading

Budget 2016: Royalty payments – Enhanced withholding tax rights

As part of the Government’s crackdown on profit shifting by multinationals from the UK to low or no-tax jurisdictions, the Chancellor has announced in Budget 2016 a package of enhanced withholding tax measures which are designed to ensure that companies are not able to use intragroup royalty payments for avoidance…. – Continue reading

Lawmakers Quiz Apple, Google, IKEA and McDonald’s Over Tax Avoidance

In their latest attempt to try to stamp out tax avoidance by multinationals in the European Union, lawmakers are set to question Apple, Google, IKEA and McDonald’s over their tax affairs as EU member states fail to agree a common tax policy. Lawmakers in the EU have struggled to prevent… – Continue reading

Special Report Looks At European Anti-Tax Avoidance Package

Thomson Reuters Checkpoint has just released a special report, European Commission Presents Anti-Tax Avoidance (ATA) Package, summarizing the ATA Package to help businesses plan for the latest developments in advance of implementation. On January 28, 2016, the European Commission presented its Communication on the Anti-Tax Avoidance Package. The goal of… – Continue reading

IRS now allows Cuban tax credit

President Barack Obama is heading to Cuba next week. When Air Force One lands on that island nation on March 20, Obama will become the first U.S. commander in chief to visit Cuba in 88 years. In advance of that historic visit, which the administration hopes will eventually lead to… – Continue reading

States vie with feds to punish company moves abroad. But does it work?

State lawmakers are getting into the act of demonizing corporate inversions even though there is not much they can do to stop them. Corporate inversions, in which U.S. companies merge with or are acquired by an overseas business, are a hot topic on the campaign trail and in the halls… – Continue reading

Tax tensions between the US and Europe hit new high

In the final session of the two day Global Tax Conference at Dublin Castle yesterday, a senior Canadian tax advisor used the analogy of children playing football to describe the relationship between multinationals and government when it comes to tax. In a kids football match, he said, when the ball… – Continue reading

Where next for Corporation Tax?

The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading

How Sanders and Trump Aim to End Offshore Corporate Tax Havens

Fortune 500 firms may be avoiding $695 billion in U.S. income taxes on $2.4 trillion held offshore. What do Bernie Sanders and Donald Trump have in common? Both seek an end to the use of offshore tax havens by corporate America. Bernie Sanders’ plan ends the ability of corporations to… – Continue reading

Liechtenstein government approves tax treaty with Switzerland

A tax treaty between Liechtenstein and Switzerland has been approved by the Liechtenstein government and transmitted to Parliament for consideration, the Liechtenstein government announced March 9. The government said that the treaty, which would replace a 1995 agreement between the countries, has also been approved by the Swiss Federal Council… – Continue reading

EU sharpens focus on tax of multinationals

EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading

Uzbekistan, Finland sign protocol to double taxation avoidance agreement

Uzbekistan and Finland signed a protocol on amendments to the Uzbek-Finnish intergovernmental agreement on avoidance of double taxation and prevention of income tax evasion, the Uzbek foreign ministry’s statement posted on its website said. Uzbekistan and Finland signed the agreement on the avoidance of double taxation and prevention of income… – Continue reading

OECD and ICC Agree on Implementation of BEPS in the Developing World

The International Chamber of Commerce (ICC) has expressed deep approval for the Organization for Economic Cooperation and Development’s (OECD) plan to allow all countries to participate in its Base Erosion and Profit Shifting (BEPS) plan. BEPS is an international policy proposal designed to counteract the negative effects of multinational companies’… – Continue reading

EPF tax row: Will it lead to double taxation?

Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading

Verdict corner: DTAA or domestic law?

Retrospective amendments to domestic laws cannot override international treaties In a judgment that will have a far-reaching impact on double taxation issues, the Delhi High Court has held that Parliament cannot change the terms of an international treaty by bringing in amendments in the domestic law, and any such executive… – Continue reading

India clicks on digital economy with equalisation levy

While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading

Forget Panama, try Belgium for a cozy tax deal

The European Commission has concluded that selective tax advantages granted by Belgium under its ‘excess profit’ tax scheme are illegal under EU state aid rules. The European Commission is looking at Member States to assess compliance with EU state aid rules in the context of aggressive tax planning by multinationals,… – Continue reading

ICC Chamber of Commerce : welcomes OECD plan to include developing countries in implementation of BEPS

The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD) plan to allow all countries to participate on an equal footing with OECD and G20 countries in the implementation of the OECD/G20 Base Erosion Profit Shifting (BEPS) plan. The framework announced by the OECD early… – Continue reading

A closer look at the flat tax

Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading

Govt negotiating issues relating to DTAA with Mauritius

Outstanding issues relating to the existing Double Taxation Avoidance Agreement (DTAA) are under negotiation between India and Mauritius through the mechanism of Joint Working Group (JWG), Parliament was informed today. “India has proposed changes in the existing DTAA to address concerns relating to treaty abuse, around tripping of funds, double… – Continue reading

No double taxation agreement with Panama; Maltese domicile subject to tax on worldwide income

Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading

Pakistan, Czech Republic implement convention to avoid double taxation

Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading

Union Budget 2016 – International tax proposals

With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading

Talking Tax in Shanghai

In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading

Important changes and developments in German double tax treaties

1. New double tax treaty between Germany and the Netherlands: tax authorities now bear burden of proof regarding tax- evading or tax-avoiding arrangements A new Double Tax Treaty (DTT) has been in place between Germany and the Netherlands since 01 January 2016. Art. 23 of the DTT introduces an important… – Continue reading

Using tax money to raise taxes

If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading

Double taxation avoidance treaty with Qatar: What is in it for Nigeria?

The federal government of Nigeria and Qatar have signed an agreement for the avoidance of double taxation on income and capital gains for investments between the two countries. In addition to the elimination of double taxation on business income, similar treaties between Nigeria and other countries provide for a lower… – Continue reading

Rationalise taxes on media, entertainment sector: Experts

Budget 2016 should rationalise entertainment tax, exempt newsprint from VAT and end double taxation on temporary transfer of movie rights to television channels, experts said. “Currently, entertainment industry players such as DTH and cable service operators are reeling under the heavy burden of multiple taxation and levies such as licence… – Continue reading

BEPS Action Plan 3: Designing effective controlled foreign company rules

A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading

Are all FDIs real foreign investment?

While the various reforms initiated by the Centre has led to a significant increase in FDI inflows into India, the Economic Survey feels the need for a closer examination of such FDI flows to determine whether there has been any instances of tax evasion. The survey noted that out of… – Continue reading

Experts hail withdrawal of ‘unworkable’ withholding tax

THE withdrawal of a withholding tax on service payments to foreigners, decried by many as unworkable, has been widely welcomed. The Treasury acknowledged that the tax had introduced “unforeseen issues, uncertainty on the application of domestic law and taxing rights under tax treaties”. The withholding tax was introduced into legislation… – Continue reading

Budget 2016: How base erosion and profit shifting (BEPS) brings HR function into focus

Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading

Zambia signing its way out of tax revenues-ActionAid Zambia

A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading

UK tops global table of damaging tax deals with developing countries

Treaties limit the tax poorer nations can place on British companies doing business within their borders, says ActionAid. The UK has signed a high number of tax deals with some of the world’s poorest countries, potentially depriving those states of millions in tax revenues every year, according to an analysis… – Continue reading

Budget 2016: Will the govt amend domestic tax laws to help the bleeding infrastructure sector

If January is a month of New Year resolutions, February can be said to be a month of New Financial Year expectations with Indian Government announcing its fiscal policy strategy, including taxation regime for the next financial year. The Union Budget of 2015-16 was the first full budget presented by… – Continue reading

Countries that accept BEPS minimum standards may participate in global tax effort, OECD says

Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according to a plan agreed to by the OECD today. The OECD’s framework for BEPS plan implementation, to be… – Continue reading

Taxation reform has to be holistic

The government reportedly wants to extend to three years the holding period for investments in listed shares to qualify for capital gains tax exemption. This accepts the need to change the present capital gains tax regime but might not be the best way to go about it. It would discriminate… – Continue reading

BIR’s five-year plan outlines tax administration improvements

THE BUREAU of Internal Revenue (BIR) has released the details of its strategic plan reaching well into the next government, by which it intends to effect improvements in tax administration. BIR Commissioner Kim S. Jacinto-Henares on Feb. 15 issued Revenue Memorandum Order No. 6-2016 detailing the bureau’s Strategic Plan 2016-2020…. – Continue reading

Tanzania: Information Exchange With Tax Bodies

Double tax treaties enable competent authorities of the treaty partners to exchange important tax information necessary for implementing the treaty or the domestic laws on taxes of every kind and description imposed. For instance, exchanges of information may be made regarding tax avoidance by companies of the contracting states.Nevertheless information… – Continue reading