Category: Tax treaties

UAE MoF and UAQ FTZ sign MoU on international OECD tax regulations

The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading

Royalty, technical fee: PJBF asks FBR to de-notify FED levy

Pakistan-Japan Business Forum has recommended to the Federal Board of Revenue (FBR) to immediately de-notify Federal Excise Duty (FED) on royalty and technical fee, which is now chargeable under the provincial legislation promulgated in Sindh, Punjab and KP, as sales tax on services. Sources told Business Recorder on Saturday that… – Continue reading

Royalty, technical fee: PJBF asks FBR to de-notify FED levy

Pakistan-Japan Business Forum has recommended to the Federal Board of Revenue (FBR) to immediately de-notify Federal Excise Duty (FED) on royalty and technical fee, which is now chargeable under the provincial legislation promulgated in Sindh, Punjab and KP, as sales tax on services. Sources told Business Recorder on Saturday that… – Continue reading

Australian trade minister: FTA with GCC ‘possible within months’

Australia and the GCC countries may only be a few months away from signing a landmark Free Trade Agreement (FTA) deal “if a decision is made quickly,” with such a deal having multiple benefits for various Gulf-based businesses and stakeholders, said Australia Trade and Investment Minister Andrew Robb. Speaking to… – Continue reading

Senate tax inquiry: Google, Apple, Microsoft policies highlight golden days of tax laxness

There was a moment on Tuesday evening – hours before the first public hearing of the Senate inquiry into corporate tax evasion – when Treasurer Joe Hockey and his advisers should have sensed a firestorm approaching. Sandwiched between a story on a Gold Coast diet blogger accused of pinching other… – Continue reading

France, German sign double tax treaty changes

BERLIN: The Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also impacts foreign investments… – Continue reading

Investment in real estate: France-German double tax treaty changes

On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also… – Continue reading

Apple, Google Reject ATO’s Tax Avoidance Claims

Apple Australia follows Australian transfer pricing law and pays all of its taxes due in the Australian market in accordance with the law, Tony King, the Managing Director of Apple Australia, told the Senate Inquiry on corporate tax avoidance and minimization on April 8, 2015. In his opening remarks before… – Continue reading

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading

Government to review gas producers’ taxation – draft budget resolution for 2016

The Ukrainian government will review the system of taxation of gas production companies irrespective of their form of ownership. This is stipulated in the draft guidelines of Ukraine’s budget policy, or the budget resolution, for 2016, which was tabled by the Cabinet of Ministers in parliament. Among the other priorities… – Continue reading

Experts warn over tax devolution

Scottish Government must work closely with councils to ensure devolution of taxation powers to Scotland brings tax and welfare systems together, according to experts. The Chartered Institute of Taxation (CIOT) also warned draft legislation could have ‘unintended complexities’, leading to double taxation on foreign income and forcing more Scottish taxpayers… – Continue reading

Switzerland: Tax Briefing – Switzerland Takes Next Steps Towards Automatic Exchange Of Information In Tax Matters (AIA)

1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading

Tax Treaty Changes Boost HK-Shanghai Stock Trading

Hong Kong Exchanges and Clearing Limited’s securities market turnover has risen to a record high, and the recent signing of the fourth Protocol to the China-Hong Kong double taxation agreement (DTA) will further boost trading activity through the Shanghai-Hong Kong Stock Connect (SHKSC) program. Hong Kong Exchanges and Clearing Limited’s… – Continue reading

Tourism, rise in Thai govt spending set to drive economic growth

BANGKOK: — IN SPITE of global economic sluggishness dampening overseas shipments this year, the Thai economy should grow more strongly during the current quarter, driven by tourism growth, rising government spending and recovering exports, ministers said yesterday. At the annual meeting of the Thai National Shippers Council, Deputy Prime Minister… – Continue reading

Cheers greet proposed changes for managed investment trusts

Proposed changes to Australia’s managed investment trust regime have been met with cheers from the investment community as they welcome the boost in certainty and tax treatments. The government revealed the long-awaited changes to Australia’s MIT tax system on Tuesday, and expects to create a new standalone regime that will… – Continue reading

China’s pre-emptive strike on OECD profit-shifting initiative

China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading

Google, Apple and Microsoft defend tax set-up that shifts revenue offshore

Executives tell Senate inquiry paying tax overseas for Australian sales is how the global tax system works, while News Corp Australia demands Netflix pays GST Senior executives from three major tech firms have defended corporate structures which allow most of the revenue from their Australian operations to be taxed in… – Continue reading

Extending dividend benefits to foreign investors may address competition concerns

The Federal Government has floated the idea of lowering the corporate tax rate – arguing the current rate of 30% is not internationally competitive. The rationale is that globalisation makes capital perfectly mobile and the marginal non-resident investor in Australian companies will go where corporate tax rates are lowest. At… – Continue reading

OECD rules will hurt cross-border funds, forum told

Draft plans to remove tax benefits for cross-border funds to eradicate Base Erosion and Profit Sharing could significantly impact investment into Ucits, the Alfi conferences hears. New draft OECD rules designed to combat Base Erosion and Profit Sharing (Beps) could have dire unintended consequences for cross-border funds, warned Roger Exwood,… – Continue reading

AM 2015-01—does previously taxed income “tier up” to a domestic corporate shareholder?

Introduction In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the corporate shareholder’s “earnings and profits” immediately or only when the earnings are actually… – Continue reading

Experts caution Australia on unilateral ‘Google tax’

Taxation experts have warned against unilateral action on corporate tax avoidance, telling a Senate Economics Committee Australia should be proactive and show leadership in the OECD and G20 tax processes already underway. The inquiry, initiated by Greens leader Christine Milne, is exploring tax avoidance and aggressive minimisation by corporations registered… – Continue reading

Malta first to enable overseas pension freedom

Malta has become the only jurisdiction to offer full UK-style pension freedoms for British ex-pat savers in qualifying registered overseas schemes, after a deal forged last week between the country’s financial regulator, reports the FT Adviser. One provider, TMF Group, has announced it has reached agreement with the Malta Financial… – Continue reading

Singapore doesn’t condone tax abuse, MOF says

Singapore does not condone any abuse of its tax system, a Ministry of Finance (MOF) spokesman said on Tuesday, in response to a Straits Times query following media reports that the Australian government is pursuing global miners BHP Billiton and Rio Tinto for channelling billions of dollars in iron ore… – Continue reading

Google says give R&D tax breaks to small techies, not big guys

Tax breaks for research and development should be targeted to smaller technology start-ups, rather than big companies that will most likely make the investments regardless of incentives, Google Australia will tell the senate inquiry into corporate tax avoidance. Google Australia’s managing director, Maile Carnegie, will be appearing before the inquiry… – Continue reading

QROPS for US Residents – FATCA & IRS Compliant

For British pension holders in the US, transferring into a Qualifying Recognised Overseas Pension Scheme (QROPS) is now commonplace. These pension solutions are widely accessible to all US residents or nationals who have accrued pensions from their time working in the UK, and are an invaluable aspect of financial planning… – Continue reading

Board of Adjustment Annulled the Reassessment Decision against Nokian Tyres Plc Concerning Tax Years 2007-2010

HELSINKI–(BUSINESS WIRE)–Regulatory News: Nokian Tyres plc (HEX:NRE1V) Stock Exchange Release 7 April 2015 3:15 p.m. Board of Adjustment annulled the reassessment decision against Nokian Tyres plc concerning tax years 2007-2010 The Board of Adjustment annulled the reassessment decision from the Tax Administration, according to which the Company was obliged to… – Continue reading

The ultimate pension freedom: Retire in Portugal and reduce your tax

New freedoms mean you can move your pension abroad. We show you where you’ll pay the least tax It is the ultimate dream for many people – to work hard, build up a nest egg and retire abroad to a climate with year-round sunshine. Now there is an added financial… – Continue reading

EU studies four countries over banks’ deferred tax assets

(Reuters) – European Union regulators are scrutinizing four EU countries’ treatment of banks’ deferred tax assets (DTAs) to see if they constitute potentially illegal state aid, the European Commission said on Tuesday. The EU executive said it had contacted authorities in Spain, Italy, Portugal and Greece following requests from some… – Continue reading

Australian Foundation Investment Company gives tax grab warning over dividends

MANY retirees could be forced on to age pensions if they lose tax credits on dividends, Australia’s biggest listed investment company has warned. Australian Foundation Investment Company general manager Geoff Driver says retirees would have less income if the dividend imputation system were scrapped. Higher demand for age pensions would… – Continue reading

Miners accused of avoiding tax in boom

Urgent changes are needed to Australian tax laws, say experts, amid claims BHP Billiton and Rio Tinto avoided paying billions of dollars in tax during the mining boom. The Australian Tax Office has the mining giants in its sights over claims they have been saving more than $750 million a… – Continue reading

News Corp CEO Julian Clarke rejects tax avoidance claim

Allegations that News Corp engaged in an aggressive tax avoidance scheme have been strongly rejected by the company. News Corp Australia chief executive Julian Clarke said in a statement: “This claim is based on a fundamental misunderstanding of the nature of these transactions, US and Australian tax treaties and applicable… – Continue reading

Vatican Bank: Haven For Money Laundering & Tax Evasion No More

Pope Francis is sweeping off clean the Vatican bank, which for many years has been cloaked with controversy for allegedly providing a safe haven to Italian individuals who laundered money and evaded taxes. On Wednesday, the Holy See’s signed tax treaty with the government of Italy — which obliges parties… – Continue reading

Azerbaijan can become economic bridgehead for Arab countries

A serious need emerges, amid the global political and economic crisis, for the dialogue among religions, cultures, different political forces, and an important role in this process is in recent years played by Azerbaijan. In this regard, the Azerbaijani President Ilham Aliyev’s visit to Saudi Arabia is significant. It is… – Continue reading

New Russian CFC Rules Will Impact Inbound U.S. Tax Planning

According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth abroad. The amount of private net capital flowing out of Russia hit $120… – Continue reading

OECD discussion draft considers Controlled Foreign Corporation Rules

On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading

India sends out nearly $6-billion worth of tax notices to foreign funds

Till March 31, close to 100 FIIs got notices from the Tax Department for a controversial Minimum Alternate Tax (MAT) of 20 per cent, while they are now being followed up with Assessment Orders. In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to… – Continue reading

Africa loses $528.9 billion to illicit transfers in a decade

It has been revealed that illicit financial transfers are draining Africa of massive resources needed to uplift its majority poor from the claws of poverty and provide both productive and social infrastructure for development. The African Civil Society Circle, a group of nine civil society organizations and think tanks from… – Continue reading

Developments in the Luxembourg Financial Sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind Luxembourg alternative investment fund managers (AIFMs) and non-EU AIFMs that market alternative investment funds (AIFs) in Luxembourg under… – Continue reading