Category: Double Tax Treaty

Black money: Jethmalani writes strong letter to Jaitley

India Blooms News Service New Delhi, Oct 24 (IBNS): Supreme Court advocate Ram Jethmalani, who was also an ex-BJP member, has written a letter to Finance Minister Arun Jaitley accusing him of not taking proper steps to bring back black money. n his letter, Jethmalani has slammed Jaitley’s stand that… – Continue reading

Interest deductions: the new war on base erosion

ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading

The Singapore-India Connection: A Robust Past and a Compelling Future

In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India’s Department of Industrial Policy & Promotion peg Mauritius and Singapore as the top two destinations through which foreign direct investment and private equity capital is routed… – Continue reading

Swiss bank secrets begin to emerge

Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading

Tax breaks for rich foreigners under fire in Switzerland

Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading

Luxembourg: Update Of The OECD Model Tax Convention

On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading

Switzerland and Argentina closer to deal on double taxation and sharing tax information

Switzerland took a step forward on implementing its double taxation agreement (DTA) with Argentina as the Federal Council adopted the dispatch on the deal and submitted it to parliament for approval. Meanwhile, in Argentina the agreement has already been passed by the Foreign Affairs and Budget Committees of the Lower… – Continue reading

IMDO Launch Report on Irish Tonnage Tax Opportunities for International Shipping Industry

IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading

Irish Budget 2015 – Rate, Regime, Reputation

Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading

Lobby sues Treasury CS over ‘illegal’ tax deal with Mauritius

A tax civil society has sued National Treasury Secretary Henry Rotich over an ‘illegal’ agreement signed with Mauritius, in a major litigation that could affect thousands of companies operating in Kenya. The suit filed at the High Court by Tax Justice Network-Africa (TJN-A) demands that Rotich withdraws a taxation treaty… – Continue reading

Arab ambassadors, Brazilian FM convene

The meeting took place at the official residency of the Egyptian ambassador, in Brasília, and focused on ways to further trade ties between Brazil and the Arab countries. Marcos Carrieri* marcos.carrieri@anba.com.br São Paulo – Ambassadors and chargés d’affaires from 18 Arab countries and the Arab League met last Thursday (9th)… – Continue reading

Worldwide: OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan

As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading

Kenya: KRA After Sh30 Billion in Audit of Companies

The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

Asia-Pacific’s developing nations raise low govenment revenue: United Nations

NEW DELHI: Developing countries in Asia Pacific region are less successful in raising government revenue but greater regional cooperation can strengthen resource mobilisation, a report has said. “Countries across the Asia-Pacific region have significant potential for enhancing tax revenues … taxation is primarily a domestic policy issue, there are also… – Continue reading

UK government promises early consultation on new multinational tax avoidance rules

The UK government will shortly set out how it plans to implement globally agreed rules to prevent multinational companies from using artificial techniques to significantly reduce their tax bills, it has announced.06 Oct 2014 Tax Tax Disputes and Investigations UK Europe It has confirmed that it will consult on the… – Continue reading

It’s Very Difficult To See How George Osborne’s Google Tax Could Possibly Be Legal

George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading

The Skinny on Corporate Inversions

Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading

Mauritius, India in talks to address tax treaty concerns: FSC

PORT LOUIS: Dispelling ‘misperceptions’ that Mauritius is a tax haven, its financial sector regulator has said the island nation is in discussions with India to address concerns and make changes to the bilateral tax treaty. Emphasising that the country provides stability and predictability for investors, Mauritius’s Financial Services Commission (FSC) sought to… – Continue reading

Switzerland Seeks To Relieve Double Tax On PEs

The Swiss Federal Council has launched a consultation on changes to the flat-rate tax credit, which seeks to ensure double tax relief for permanent establishments of companies that are located in Switzerland. The proposed change affects permanent establishments in Switzerland that are part of a company domiciled in a country… – Continue reading

Obama Treasury’s Corporate Inversion Regulations Simply Won’t Work

The Treasury Department today came out with a series of arcane new tax regulations in the hopes of stemming corporate inversions. Inversions happen when U.S. companies merge with a foreign company while usually retaining U.S. operations. Their purpose is to avoid punitive U.S. double taxation on income earned overseas. The… – Continue reading

Brazil, U.S. sign tax pact frozen by spy scandal

Brazil signed a tax information exchange agreement with the United States to prevent tax evasion, the South American country’s finance ministry said on Tuesday, a step long sought by businesses that was held up by a spy scandal last year. The pact opens the door to a tax treaty to avoid the double… – Continue reading

Study: Uganda Losing Money to Double Taxation Treaties

Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but not… – Continue reading

Key Tax Considerations of Sending Employees Overseas

The issue of international assignees was, for a long time, limited to a small number of companies – meaning only those that operated on an international scale. But in recent years, global expansion has shifted into focus for the larger business community. As a result, the challenges and best practices… – Continue reading

India Continues Tax Dispute With Cyprus and Mauritius

India has seemingly reached an impasse with both Cyprus and Mauritius over the re-negotiation of their respective double taxation avoidance agreements (DTAA). For the former, the disagreement relates to Cyprus’s status as a notified jurisdictional area (NJA) in India, whilst for the latter, it pertains to the update of their… – Continue reading

FOURTH AMENDMENT OF THE LUXEMBOURG AND FRANCE DOUBLE TAX TREATY

The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”)…. – Continue reading

Investment in French real estate: France-Luxembourg double tax treaty changes

On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate. Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating… – Continue reading

United Kingdom: Recent Chinese Tax Changes Affecting The Shipping Industry

On 1 August 2014, the “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (2014 No.37 Notice, the “New Regulations”) came into force. The New Regulations could have a significant impact on owners as they seek to streamline and tighten up the regulations in respect of… – Continue reading

Federal Court hands down software tax decision

The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading

Who owes where?

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Your tax liability in the country in which you live and/or work depends on the tax laws of that particular country. Countries can levy taxes on a residence basis, because you live in the country,… – Continue reading

India Eyes Tax On £350 Billion Cash Hidden Offshore

The Indian government’s bid to unearth black money stashed away in hidden offshore accounts is starting to pay off. The government believes around £350 billion is hidden in undeclared bank accounts and investments outside the country and wants to bring the tax owed on the money back to India. Nine… – Continue reading

The cost of cutting ties with Uncle Sam soar: Tim Harper

Americans living in Canada are in a rush to renounce their citizenship in the face of Washington’s invasive tax grab. OTTAWA – Thomas Jefferson is famously believed to have defined the price of freedom as eternal vigilance. The price of freedom from Uncle Sam is a lot steeper. Faced with… – Continue reading

No request to retrieve ‘$200 billion’ in Swiss banks, says Swiss envoy

ISLAMABAD: Pakistan has not requested for negotiations on exchange of information for restitution of any ill-gotten money presumably stashed in Swiss banks, said Swiss Ambassador to Pakistan and Afghanistan Marc George on Monday. The statement from the Swiss ambassador follows claims by Finance Minister Ishaq Dar that talks would be held with… – Continue reading