Category: Tax treaties

Netherlands Revises Treaties To Support BEPS Work

The Government of Netherlands has successfully negotiated the inclusion of anti-abuse provisions, aimed at combating cross-border tax avoidance, in tax treaties with Ethiopia, Ghana, Kenya, Malawi, and Zambia. At present, talks are being held with another seven countries and new agreements with several other countries are expected to be concluded… – Continue reading

Isle of Man: Isle of Man’s TIEA With Italy Now In Force

The Isle of Man’s Agreement for the Exchange of Information Relating to Tax Matters with the Government of the Italian Republic entered into force on 10 June 2015. The agreement was signed on 16 September 2013 in London between Eddie Teare, the Isle of Man’s Treasury Minister, and His Excellency… – Continue reading

Insurance tax changes loom on the horizon

Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading

Hong Kong chides EU for new tax blacklist

Hong Kong’s Government has expressed its regret that the European Union included the territory in its list of non-cooperative tax jurisdictions, saying that criticism of its transparency in tax matters is “totally unfounded.”, reports Tax News. The EU tax blacklist was included in the European Commission’s new Corporate Tax Reform… – Continue reading

Poland removes Bermuda from ‘blacklist’

A controversial Euro list of dodgy tax jurisdictions that included Bermuda has been dealt a blow after Poland said the Island should not have been included on its submission. The move came after the European Commission unveiled the 30-jurisdiction ‘blacklist’ of non-cooperative tax jurisdictions singled out by member states. Poland… – Continue reading

Switzerland: TAX NEWS: Swiss Voters Reject Introduction Of Swiss Federal Inheritance Tax – Current Cantonal Inheritance And Gift Tax System Remains Unchanged

After a controversial political debate, the Swiss voters have decided to reject the popular initiative to introduce a federal inheritance tax with a vast majority of 71.7% in the popular vote of 14 June 2015.. The 26 Cantons also unanimously rejected the the popular initiative. The clear result shows that… – Continue reading

U.S. Treasury attempts to influence OECD’s BEPS initiative via proposed changes to U.S. model treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading

Complex tax laws a goose to overseas firms

Someone once said that a good tax system enables the government to pluck the feathers from the taxpaying goose with the least amount of hissing, says Rod Houng-Lee. The least amount of hissing occurs when the law is simple and clear. The hissing increases exponentially when the law is more… – Continue reading

Crackdown on multinational tax avoidance likely to be thwarted, says expert

The G20’s efforts to crack down on multinational tax avoidance are likely to be defeated by national self-interest, particularly from the United States, one of Australasia’s top tax advisers says, reports the Sydney Morning Herald. Rod Houng-Lee, formerly Asia Pacific Tax Leader head of tax in Asia Pacific for big-four… – Continue reading

Jaitley assures US investors of a stable policy regime

Washington, June 21 (IANS): Indian Finance Minister Arun Jaitley is wooing American investors with twin assurances — more economic reforms and a stable policy regime with no intention to legislate or apply laws retrospectively. Jaitley has held talks with US Treasury Secretary Jacob Lew, Commerce Secretary Penny Pritzker and US… – Continue reading

Mauritius to act against black money: Finance Minister Seetanah Lutchmeenaraidoo

NEW DELHI: Mauritius has offered to put in place stringent conditions for investors seeking benefits under its tax treaty with India to weed out post-box operations, addressing a key concern of New Delhi that has been attempting to amend the agreement for years. “We don’t want investors to open shell… – Continue reading

Mauritius assures India will not allow shell companies

Lutchmeenaraidoo, who met foreign minister Sushma Swaraj, played down the issue of misuse of the India- Mauritius Double Taxation Avoidance Convention (DTAC). Mauritius will make it difficult for shell companies using a liberal and controversial bilateral tax treaty with New Delhi to evade taxes in India, said the island nation’s… – Continue reading

Professions resist key components of OECD tax plan

Accounting and legal professions in Ireland oppose major strands of business tax plan Key strands of the Organisation for Economic Co-operation and Development plan (OECD) to overhaul global business tax rules have run into resistance within the accounting and legal professions in Ireland. A submission this week to the Paris-based… – Continue reading

South Africa: Country-Mauritius Tax Treaty Comes Into Force

Pretoria — Government has gazetted the South Africa-Mauritius tax treaty which came into force at the end of May, said National Treasury. “This new treaty reflects changes in the tax policies of the two countries and is in line with international best practices to deal with tax abuse as outlined… – Continue reading

European Union Blacklists Panama as Tax Haven

The European Commission has added Panama to its blacklist of countries designated as tax havens over a lack of support for anti-tax fraud and evasion efforts. The European Union’s executive Commission unveiled the list in the introduction to its action plan to fight tax fraud. The blacklist consists of 30… – Continue reading

Cyprus: The New Cyprus-Iceland Double Taxation Agreement

With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading

Global net closes on tax dodgers

International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading

Cyprus: The Potential Impact Of Russian De-Offshorization Legislation On Cyprus Holding And Finance Structures

Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading

‘Surprise’ at Guernsey inclusion on EU ‘non-cooperative’ blacklist

Guernsey’s Chief Minister and Commerce and Employment Minister have expressed their astonishment that Guernsey has been included on a list of 30 so-called ‘non-cooperative’ non-EU jurisdictions, which was published today, reports Guernsey Finance. The list consolidates national tax ‘blacklists’ as they stood six months ago, and includes any jurisdiction on… – Continue reading

Allegation of Hong Kong as non-cooperative tax jurisdiction totally unfounded

Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government today (June 18) expressed regret over the inclusion of Hong Kong in the list of non-cooperative tax jurisdictions published by the European Commission. “Hong Kong has all along been supportive of international efforts to enhance tax transparency and combat… – Continue reading

Proposed U.S. Model Treaty Provisions May Dramatically Alter International Tax Landscape

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading

New tax treaty with Mauritius may affect cross-border investment

THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading

Brussels to announce measures against corporations’ ‘sweetheart’ tax deals

Politically incendiary proposals will set sights on multinationals’ tax planning with EU states and 30 worst offending havens could be officially blacklisted Officials in Brussels will on Wednesday announce a series of measures designed to stamp out the toxic culture of secret, sweetheart tax deals for multinationals which prevails in… – Continue reading

Fund administration – opportunities for offshore and alternative investment funds

Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of fund… – Continue reading

Birth of a New Era in Private Wealth

As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading

Divisions in US over OECD corporate tax proposals

Senior Republicans voice concerns over Obama administration’s response to plan Political divisions are opening up in Washington over the US response to the overhaul of international tax rules by the global powers, an initiative with big implications for Ireland’s corporate tax regime. The Republican leaders of the two tax-writing committees… – Continue reading

Australia, Germany in tax talks

AUSTRALIA and Germany are starting negotiations to update a tax treaty between the two countries that stretches back 40 years. TREASURER Joe Hockey says the discussions will focus on maximising the efficiency of the trade and investment relationship with the world’s fourth largest economy and Australia’s tenth largest trading partner… – Continue reading

Nigeria Sends Clear Signal of Getting Serious on Tax Evasion, Avoidance

With revenue from petroleum taxes at its lowest point in fifteen years, Nigeria is under even more pressure to tackle tax evasion and pursue other revenue enhancing initiatives. Indeed, experts have found that tax evasion plays a significant part in the over $50 billion that the continent loses every year… – Continue reading

Treaties likely on exchange of tax information

ISLAMABAD: Several amendments have been proposed to the tax laws in the Finance Bill 2015-16 to empower the federal government to enter into agreements for exchange of tax-related information with provinces and other countries. The new sections proposed to be inserted in the Finance Bill will empower Islamabad to enter… – Continue reading