Category: Tax treaties

Treaty shopping may see companies going home empty handed, says Deloitte

The implementation of stricter rules by the Organisation for Economic Cooperation and Development (OECD) surrounding tax treaty benefits could see these benefits not being granted as easily as they were in the past, says professional services firm Deloitte. “The discussion surrounding ‘inappropriate circumstances’ relating to the issues of treaty shopping… – Continue reading

Swiss team to discuss revision of dual taxation treaty: Visit likely by August-end

A Swiss delegation is likely to visit Pakistan by August-end to discuss the possibility of re-negotiating and upgrading treaty on Avoidance of Double Taxation between Pakistan and Switzerland. It is reliably learnt on Tuesday that Pakistan is set to re-negotiate and upgrade treaty on Avoidance of Double Taxation with Switzerland… – Continue reading

Malta, Moldova Sign Double Tax Agreement

Maltese Foreign Affairs Minister George Vella met with Moldavian Deputy Prime Minister Natalia Gherman to sign a dual taxation treaty (DTT) and a joint declaration, according to a press release issued by the Maltese Government. The joint declaration confirms Malta’s support for Moldova’s bid for greater integration in the EU…. – Continue reading

Mauritian firm Ireland Blyth says Indian tax rules affecting investment

Mauritian conglomerate Ireland Blyth IBLP.MZ says uncertainty over new tax rules by key trading partner India has affected its business by putting off investors using the Mauritius financial center to invest in India. Nicolas Maigrot, chief executive of the group which has a wide range of interests in financial services,… – Continue reading

Cyprus: Imminent Entry Into Force Of The New Double Taxation Agreement Between Cyprus And Spain

Article 27 of the new double taxation agreement between Spain and Cyprus provides that the agreement will enter into force three months after the exchange of official notifications between the governments concerned that all ratification procedures have been completed. We understand that notifications were exchanged in March, which means that… – Continue reading

FDI from Mauritius to India drying up

India had received in $8.17 bn during April- January 2012-13 Foreign Direct Investment inflows from Mauritius have almost halved during April-January period of last fiscal to $4.11 billion on fears of impact of GAAR and possible re-negotiation of the tax avoidance treaty. India had received in $8.17 billion during April-… – Continue reading

What qualifies as direct investment under Cyprus-Russia double tax agreement?

Introduction Article 10 of the Russia-Cyprus double tax agreement grants taxing rights over dividends to the state of residence of the company paying the dividends (in addition to the state of residence of the recipient). The tax that may be imposed in the state in which the dividends originate is… – Continue reading

KKR’s Entry Into Canadian Oil Patch Crimped by Tax Clampdown

Canada is clamping down on off-shore tax shelters used by private-equity funds, in a move that may curb investment in the oil and gas industry by KKR & Co. and Blackstone Group LP. (BX) The government has given private-equity firms and other interested parties until April 11 to respond to proposals tucked… – Continue reading

Corporate Tax: OECD’s Saint-Amans says “Double Irish Dutch” sandwich tax scheme will be axed

Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading

Illicit Financial Flows deprives Africa of billions of dollars

ActionAid Ghana (AAG) said Illicit Financial Flows (IFFs) was depriving Africa of billions of dollars each year, more than is received in overseas development aid or foreign direct investment combined. It said IFFs were commonly associated with criminal activity like drug dealing, smuggling or human trafficking, adding that the United… – Continue reading

Luxembourg Supports New Savings Tax Directive

Luxembourg’s Prime Minister Xavier Bettel said the conclusions adopted at the recent European Council meeting on the revised Savings Tax Directive have enabled “a green light from the Grand Duchy of Luxembourg.” He expressed his satisfaction that all 28 European Union (EU) member states reached an agreement at the latest… – Continue reading

Double taxation risk in chasing multinational companies

A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading

Black money menace

It would be surprising if Union finance minister P. Chidambaram’s threat to his Swiss counterpart — to declare Switzerland an uncooperative nation for not sharing information on the 562 Indians who allegedly stashed their black money in Swiss banks — is actually carried out. The threat has trade implications. These… – Continue reading

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies. Since 2010, French companies that have an annual turnover or gross asset value exceeding €400 million, are related to a French or foreign entity exceeding one of… – Continue reading

Multinationals face new rules on aggressive tax avoidance

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

UAE-Luxembourg ties gaining steam across all sectors

Despite bilateral trade touching $83M in 2012, the two countries have greater ambitions given the untapped opportunities that the destinations offer.  UAE Minister of Economy Sultan bin Saeed Al Mansouri stressed that the bilateral relationship between the UAE and Luxembourg is witnessing significant progress across the economy, trade and investment… – Continue reading

Vice Premier Dragnea announces start of negotiations on Romania – Hong Kong double taxation agreement

Vice Prime Minister Liviu Dragnea declared on Thursday after his meeting with the Chief Executive of the Hong Kong Special Administrative Region K.Y. Leung that Romania and Hong Kong will start negotiations for the signing of the double taxation agreement that was already discussed last summer during Prime Minister Victor… – Continue reading

Kenya Inks Deal With Seychelles To Eliminate Double Taxation

NAIROBI (Xinhua) — The Kenyan government on Monday signed an agreement with the Seychelles to phase out double taxation on companies from the two countries. Kenya’s Cabinet Secretary for Treasury Henry Rotich said the elimination of double taxation will promote flow of investments, trade and labor between the two countries. “ Kenya has… – Continue reading

Offshore taxes may slow audits for some U.S. multinationals: IRS

WASHINGTON (Reuters) – Multinational businesses that often fight with the U.S. Internal Revenue Service over their worldwide taxes may be dropped from an IRS program meant to smooth corporate audits, a senior IRS official said on Tuesday. Speaking at a conference, Michael Danilack, a deputy U.S. IRS commissioner, raised concerns… – Continue reading

Ireland’s Noonan Clarifies Corporate Tax Developments

Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading

Worldwide: Canada-U.S. FATCA Intergovernmental Agreement

On February 5th, 2014, the Canada signed an intergovernmental agreement (“IGA”) with the U.S. regarding the U.S. Foreign Account Tax Compliance Act (“FATCA”). Under the terms of FATCA, Canadian financial institutions need to report directly to the U.S. Internal Revenue Service (“IRS”) any information regarding bank accounts held by U.S…. – Continue reading

Mauritius at the Forefront of Tax-Friendly Countries for High-net Worth Foreigners

From “Tiger of the Indian Ocean” to “Cyber island”, Mauritius has turned now into a “Safe and Reliable Investment Hub” in terms of good governance as well as ethical, economic, political and social stability. Ranked 1st in Sub-Saharan Africa in the World Bank‘s Doing Business Report 2013, Mauritius offers a particularly favorable setting for doing business…. – Continue reading