Category: Withholding Tax

Tax Competitiveness in India: Changing Rules, Trends in Taxation

Ease of doing business and tax reforms are at the center of India’s growth agenda as the country pitches itself as the leading investment destination among global emerging markets. Yet, India’s tax competitiveness record remains mixed. At a time when the U.S., U.K., and Japan have slashed their corporate tax… – Continue reading

Withholding Corporate Income Tax in China

In China, withholding Corporate Income Tax (CIT) is applied to the following China-sourced incomes derived by non-resident enterprises without establishments in China, or to that derived by non-resident enterprises with establishments in China but whose income is not related to these establishments: Dividends, bonuses, and other equity investment proceeds; Interests,… – Continue reading

Banks asked to deduct up to 3pc tax on foreign funds transfer

KARACHI: Government asked banks to impose up to three percent tax on foreign funds transfer made through plastic card in a new finance bill. The finance bill for the next fiscal year of 2018/19 proposed a new advance tax levy on individuals remitting amounts abroad through credit, debit or prepaid… – Continue reading

FBR to offset exit of 0.52 million returns filers after tax exemption

KARACHI: The Federal Board of Revenue (FBR) is all set to offset a possible exit of 0.52 million returns filers from the net after the implementation of a tax exemption on certain income group from July 1, officials said on Saturday. “About 0.52 million income tax returns will be lost… – Continue reading

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying… – Continue reading

Ghana Revenue Authority to fix a 7% VAT withholding tax

The Ghana Revenue Authority (GRA) would, this year, start charging seven per cent VAT Withholding Tax on individuals and entities that transact business with the Ministries, Departments and Agencies (MDAs). “What we are seeking to do is that as a person is charging the 17.5 VAT on build-up cost of… – Continue reading

India, Kenya revise tax treaty

NEW DELHI: The Indian and Kenyan governments have revised their double taxation avoidance agreement (DTAA) to bring down the withholding tax rates, protect treaty from abuse and check tax evasion, an official statement said on Thursday. The revised DTAA was notified on February 19, said a Finance Ministry statement. “The… – Continue reading

ROHQ workers lose tax privileges

The Bureau of Internal Revenue (BIR) said employees of regional operating headquarters (ROHQ) who used to enjoy preferential tax rates, will no longer be able to avail them beginning this year. In a tax advisory, the BIR said in view of the recent amendment of the provisions of Section 25(B),… – Continue reading

Norway Advocates Global Digital Tax Solution

The Norwegian Government is considering possibilities for the taxation of multinational companies’ “value creation” in Norway, including in the area of value-added tax, although it said that it would prefer a multilateral agreement on any new measure. In a letter to the parliamentary finance committee dated January 18, Finance Minister… – Continue reading

Taxation agreement with Singapore in effect

The double tax avoidance agreement (DTA) between Cambodia and Singapore came into effect this month, helping clarify taxation rights on all forms of income arising from cross-border business activities, while minimising double taxation. On January 1 the Inland Revenue Authority of Singapore (IRAS) issued an announcement stating that the DTA… – Continue reading

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended… – Continue reading

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice… – Continue reading

AmCham EU Speaks Out Against EU Digital Tax Proposals

The American Chamber of Commerce in the European Union has criticized the proposals put forward in the European Commission’s recent consultation on options for new tax rules or a new tax on digital firms. The aim of that consultation is to help the Commission to define an approach to the… – Continue reading

UK Releases Guidance On Royalties WHT Proposal

The UK Government has released a consultation on the royalty withholding tax targeting digital firms announced in the UK’s most recent Budget. Under the proposal, the Government intends to introduce legislation in Finance Bill 2018-19 to broaden the circumstances in which certain payments made to non-UK residents have a liability… – Continue reading

Belarus-Hong Kong double taxation agreement comes into force

MINSK, 4 December (BelTA) – The double taxation agreement between Belarus and Hong Kong, a special administrative region of China, has come into effect, BelTA learned from the Belarusian Embassy in Beijing. “After Belarus and China went through the necessary domestic procedures, the Belarus-Hong Kong agreement on the avoidance of… – Continue reading

Serbia to Abolish Full Blown Withholding Tax on Non-Resident Service-Providers and Simplify Conditions for Tax Deductibility of NPL Write-Offs for Serbian Banks

The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition… – Continue reading

Proposed new UK royalty withholding tax will apply from April 2019

A new royalty withholding tax will apply from April 2019 where a non-UK resident entity making sales in the UK pays a royalty to a connected party in a low tax jurisdiction, according to a consultation document which sets out further details of the proposal, which was first announced in… – Continue reading

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the… – Continue reading

Government reduces tax load on MFIs receiving money from abroad

The Ministry of Economy and Finance (MEF) recently decided to shrink the tax burden for local microfinance institutions (MFIs) by lowering withholding tax on interest from loans acquired from abroad from 14 to 10 percent, a move that the government claims will keep the massive sector sustainable. This is the… – Continue reading

Dutch government continues with dividend withholding tax proposal and announces conditional retroactive amendment to CIT fiscal unity regime

In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal… – Continue reading

Aircraft Leasing in Russia – Key developments in Russian tax and insurance laws

Summary: With effect from 1 January 2017, a number of amendments to Russian law have come into force which will affect aircraft leasing arrangements for lessors and financiers that have aircraft leased or financed with Russian operators. These amendments have started to affect negotiations and re-negotiations of leases with Russian… – Continue reading

Grenada Gears Up For FATCA

Grenada’s Inland Revenue Division has completed a series of training exercises for its staff and the island’s financial institutions in preparation for the start of reporting under the US Financial Account Tax Compliance Act. Reporting by FIs under FATCA is governed by a November 2016 inter-governmental agreement between the US… – Continue reading

Court orders developer to reveal condo-flipper info

A Federal Court judge has approved at least one court order that will require a British Columbia developer to turn over information to tax officials about people who bought and flipped condo units before or during construction. And several similar applications are under way, reflecting the federal government’s efforts to… – Continue reading

New regulation forces Indonesians to sell their foreign shell companies

On the back of the Indonesian government’s issuance of its new controlled foreign company (CFC) regulation on July 26, many Indonesians are likely to sell their foreign shell companies because of the enforcement of double tax payments. The CFC regulation authorizes the government to charge a dividend tax on foreign… – Continue reading

Briefing: Proper plan design is way forward

International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another… – Continue reading

Tax expert says amendment to new tax law likely before implementation next year

Removal of withholding tax on G-Sec income effectively frees foreign investors paying any taxes New tax law proposes to remove 10% withholding tax on G-Secs but makes such income liable for income tax up to 24% This likely to result in sizeable leakage of tax revenue to govt. as G-Secs… – Continue reading

Foreigners in Sri Lanka Treasury bonds may not have to pay tax

ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading

Switzerland Consulting On WHT Reforms

The Swiss Federal Department of Finance is consulting on proposals to amend the Withholding Tax (WHT) Ordinance, to more clearly define the rules for non-resident taxpayers. Under the proposed reforms, “quasi-residents” will be permitted to request a subsequent ordinary tax assessment. “Quasi-residents” are employees who are not domiciled in Switzerland… – Continue reading

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading

Japan, Russia Agree New Double Tax Pact

The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading

Protocol Amending the Mexico-Belgium Tax Treaty Published

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion (“Tax Treaty”) between Belgium and Mexico was published in Mexico’s Official Journal of the Federation (Belgium publication pending). The Tax Treaty became effective in Belgium on August… – Continue reading

Panama: Panama Tax Treaties

The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading

I-T Department open to reducing withholding tax for foreign companies: Official

NEW DELHI: The Income Tax department is open to lowering the withholding tax rate for foreign companies which have income in India, a senior official said today. Central Board of Direct Taxes (CBDT) Chairman Sushil Chandra also urged firms and MNCs operating in India to pay their due share of… – Continue reading

Multinationals Warned on Coke’s $41 Million Israel Tax Claim

Israel’s $41 million tax demand from the Coca-Cola Co. on royalties from its Israeli licensee could mark the start of a wave of claims against U.S. and other multinationals with similar business operations in the country. That could lead to a conflict with U.S. and other authorities about which country… – Continue reading

Irish Committee Calls For WHT For Overseas Artists

The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading

Push to draw up Cambodia-Thai tax treaty

Representatives from the tax authorities of Cambodia and Thailand have agreed in principle to speed up a proposed double taxation agreement that would protect their nationals from dual taxation and encourage bilateral investment. The agreement was made last week during a two-day consultation workshop in Bangkok for tax officials from… – Continue reading

Draft modifications to tax provisions applicable to foreign companies with poem in India

Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of… – Continue reading

Memo to: real estate vendors – if the sale price is $750,000 or more you need a Tax Clearance Certificate for settlement

In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more… – Continue reading

Malta Pushes to Ease EU Cross-Border Interest, Withholding Tax

European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial… – Continue reading