Category: Tax treaties

Singaporean – Ecuadorian DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Ecuador for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Singaporean – San Marinese DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of San Marino for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Singaporean – Seychellois DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Liechtenstein – Czech Republic: Tax Treaty Enters Into Force

The Income Tax Treaty between Liechtenstein and the Czech Republic entered into force on 22 December 2015. Its provisions will apply from 1 January 2016. The Treaty was signed on 25 September 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0% if the beneficial owner… – Continue reading

MoU signed with BD, Bahrain

Bangladesh and Bahrain have signed three instruments in Manama to further strengthen cooperation in various fields between the two countries. The instruments are Agreement on the Reciprocal Protection and Promotion of Investment, Agreement on the Avoidance of Double Taxation and a MoU on Foreign Office Consultations. The first two instruments… – Continue reading

Philippines, Germany Update Tax Treaty

Germany and Philippines have completed the necessary domestic ratification procedures to bring their new double tax agreement into force. The two nations exchanged instruments of ratification on December 20 to replace their existing treaty, which was concluded in 1983. Negotiations on the upgraded treaty were concluded on July 20, 2012,… – Continue reading

Mohammed receives Slovak Prime Minister

His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, on Monday received Robert Fico, Prime Minister of Slovakia, and members of the accompanying delegation at Zabeel Palace. During the meeting, Sheikh Mohammed accepted an invitation from the Slovak prime minister… – Continue reading

Swiss, Italy agree deal on taxing cross-border commuters

ZURICH: Negotiators from Switzerland and neighbour Italy reached agreement on Tuesday on how to tax cross-border commuters, wrapping up months of talks that aimed to help Italy crack down on undeclared foreign wealth. The accord, which must be approved by both national governments and parliaments, would see workers paying up… – Continue reading

Ministry of Finance hosts Ethiopian delegation

Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received a delegation from Ethiopia at the Ministry of Finance headquarters in Abu Dhabi. The meeting was held to discuss investment opportunities and economic cooperation between UAE and Ethiopia. The agreement on the avoidance of double taxation on income signed… – Continue reading

SARS Explains 2015 Tax Administration Amendments

On December 17, the South African Revenue Service (SARS) issued an explanatory memorandum on the 2015 Tax Administration Laws Amendment Bill (TALAB). In particular, the memorandum looks at the TALAB provisions giving effect to the collection of information from South African financial institutions (FIs), and the associated obligation on the… – Continue reading

Qatar’s National Day Observed

The embassy of the State of Qatar in Banjul were on Saturday, December 19th joined by Gambians in celebrating the oil-rich Gulf country’s National Day. Senior government officials including cabinet ministers, as well as foreign diplomats and representatives of various agencies in The Gambia graced the event. Speaking at the… – Continue reading

Developed countries erode BEPS Action Plan on Digital Economy

IT is ironic that what was almost at the centre of the BEPS project has ended up in not having a concrete agreement and with a vague promise of some review by the year 2020. One may recall that it was the big digital companies and their tax affairs that… – Continue reading

Two Little Known Tax Treaties Will Lead to Substantially More Identity Theft, Crime, Industrial Espionage, and Suppression of Political Dissidents

The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading

BOTSWANA, African tax haven?

About Botswana Botswana, a former British colony in Southern Africa, is one of the most prominent countries in Africa. The country has a strong economy,uses one of the most advanced banking systems in the continent, and maintains a stable tradition of representative democracy. After becoming independent in 1966, Botswana developed… – Continue reading

Arab League intent on increasing investments in Brazil

The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading

Relocating Canadian employees to the US: Three major tax considerations

Employees relocating from Canada to the US may face a number of complex tax-related issues. Matt C Altro, president and CEO of Canadian firm MCA Cross Border Advisors, shares his advice for companies and their relocatees on planning for, and coping with, these challenges. Talent mobility is a key issue… – Continue reading

The deal between Turkey and FATCA

Turkey’s ruling Justice and Development Party (AKP) government, in power for 13 years, has been notoriously lax and often late when it comes to implementing stringent rules controlling money in order to ensure better transparency in financial movements, halt tax evasion, prevent illicit funding and disrupt money laundering activities. That… – Continue reading

Financial Information Sharing for 2016

Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading

Financial Information Sharing for 2016

Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading

Battle of words over taxation

On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading

Luxembourg – Main New 2016 Tax Measures At A Glance

IP regime  To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading

Andorra, Malta Sign Double Tax Agreement

Andorra and Malta have signed an agreement on the avoidance of double taxation and prevention of fiscal evasion. The Government of Andorra announced on December 16 that, following two days of meetings, an agreement was signed between a delegation led by Andorra’s Secretary of State for International Financial Affairs, Claudia… – Continue reading

Russian business shifts upmarket

It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading

‘Tax rules worsen business climate’

ISLAMABAD: The World Bank says tax regulations in Pakistan are frequently altered, and unpredictable tax rules worsen the business climate and may deter potential investment. The report “Towards a more friendly tax regime: Key challenges in South Asia,” points out that South Asia’s tax regulations are complex and difficult to… – Continue reading

Brazil’s Superior Court of Justice issues decision exempting payments of services to Spain from withholding tax in Brazil

In the context of a series of recent developments on the tax treatment of cross border services payments from Brazil, the Superior Court of Justice (STJ) recently ruled that payments for services performed by a Spanish company without permanent establishment in Brazil are not subject to withholding income tax in… – Continue reading

Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud

Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading

The end of financial privacy?

Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading

EC Extends Investigation Into Apple Tax Deal

The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading

Double taxation avoidance

India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading

IP BOX: Italian and European Legal Framework

On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading

Latvian president calls for double taxation treaty with Japan

Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading

Belgian Minister of Finance sheds light on implementation of BEPS related measures

The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is… – Continue reading

British Virgin Islands: What Structure Should I Use For My Offshore Fund?

There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading

St Kitts And Nevis To Improve Tax Info Exchange

Caribbean territory Saint Kitts and Nevis has proposed legislative changes to improve its ability to exchange information with treaty partners in tax matters. The territory’s Prime Minister, Timothy Harris, explained that the changes have been prompted by an increasing number of requests from treaty partners, which he attributed to a… – Continue reading

DYK: Dividend from investing in shares of foreign companies is taxable in India

Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading

Malta: The Tax Challenges Of The Digital Economy – Article 3

Main principles of Direct Taxation – Double Tax Treaties In our third article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading