Royalty taxation shall be set at 5% and 10%. The tax rate is being raised from 2% to 5%, while the zero taxation of dividends and royalty payments are being abolished. Such are the main changes in the Convention between Ukraine and the Kingdom of the Netherlands on double taxation… – Continue reading
Luxembourg Finance Minister Pierre Gramegna has said that any special tax measures against large digital companies should respect European Union law. Gramegna made the comments during an official visit to Paris earlier this month where he held a series of working meetings with French government counterparts. “Pierre Gramegna stressed that… – Continue reading
India and Iran signed a Double Taxation Avoidance Agreement (DTAA) in February, during Iranian President Hassan Rouhani’s official visit to India. The ‘Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income’ aims to encourage the movement of investments and services… – Continue reading
High net worth residents in the UAE are increasingly applying for second passports to avail of maximum visa-free travel opportunities, expand businesses and avoid double taxation, experts have said. According to companies involved in citizenship programmes, most of the demand for second citizenship programmes is coming from Indians, Pakistanis, Syrians… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) on February 23, 2018, released the fifth edition of its Transfer Pricing Guidelines for income tax. During a public consultation held in June 2017, stakeholders asked the Ministry of Finance to provide more clarity and guidance on transfer pricing documentation (TPD) requirements, specifically… – Continue reading
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
The Senate on Monday passed on third and final reading five resolutions concurring the ratification of five treaties, including the Budapest Convention on Cybercrime which would prevent syndicates from making the Philippines a “haven” for their illegal activities. Senators also unanimously ratified four treaties covering the Philippines’ Double Taxation Avoidance… – Continue reading
India and Iran today signed an agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with regard to taxes on income. The agreement is on similar lines as entered into by India with other countries, the Central Board of Direct Taxes (CBDT) said in a statement. “The agreement… – Continue reading
ASTANA. KAZINFORM Kazakhstan has ratified the Protocol between the Governments of Kazakhstan and India on introducing amendments to the Convention on the avoidance of double taxation, the press service of Akorda reports. Head of State Nursultan Nazarbayev signed the Law of the Republic of Kazakhstan “On Ratification of the Protocol… – Continue reading
Secretary Mnuchin Commits During Congressional Testimony to Assign Treasury Department Officials to Work on Bilateral Accord WASHINGTON—Treasury Secretary Steven Mnuchin, during Congressional testimony Tuesday before the U.S. House Financial Services Committee, agreed – in response to direct questioning by Representative Brad Sherman (D-CA) – to commit Treasury Department officials to… – Continue reading
The Netherlands will seek to resume discussions towards double taxation avoidance treaties with several countries in 2018, including the United States, the Government has said. The Dutch Government will attempt to begin tax treaty talks with at least seven countries this year, including Australia, Colombia, Costa Rica, Ecuador, Morocco, Austria,… – Continue reading
U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading
U.S. Representatives David Valadao (R-CA) and Brad Sherman (D-CA) are collecting signatures on a bipartisan letter urging their Congressional colleagues to request that Secretary of the Treasury Steven Mnuchin renegotiate the existing, outdated Double Tax Treaty with Armenia, an obsolete Cold War-era accord, recognized today by the U.S. but not… – Continue reading
The heads of the Greek and Bulgarian tax authorities have met to discuss ways in which bilateral cooperation can be boosted with a view to reducing levels of tax avoidance and evasion, particularly with respect to Greek companies shifting profits to Bulgaria. “The major issue of tax avoidance by Greek… – Continue reading
The United Arab Emirates Cabinet on January 7, 2018, approved two double tax agreements concluded by the territory in 2017 with Moldova and Croatia. Double tax agreements seek to facilitate trade and investment between two or more countries by setting out the taxing rights of the territories involved, to ensure… – Continue reading
Taiwanese Premier Lai Ching-Te has directed the Ministry of Finance to work towards a Taiwan-US tax treaty. Speaking at a strategic briefing to the National Development Council on January 4, 2018, Lai noted that the US is one of Taiwan’s most important trading partners. A tax treaty would ensure that… – Continue reading
Viet Nam News HCM City – The Netherlands-based ride-hailing firm Uber International Services Holding B.V has filed a lawsuit against the HCM City tax department after it decided to forcibly collect tax, Người Lao Động (Labourer) newspaper reported. Earlier the department had sent a notice to Uber that it had… – Continue reading
India entered into three more advance pricing agreements in December, with two unilateral agreements and a bilateral APA concluded with authorities in the United Kingdom. With the signing of these agreements, the total number of APAs entered into by the Central Board of Direct Taxes totals 189, comprising 173 unilateral… – Continue reading
Vietnam has lost thousands of billions of dong in taxes as foreign enterprises, especially large-scale ones, refuse to pay based on the Double Taxation Avoidance Agreement. Massive revenue without having to pay taxes The Ho Chi Minh City Department of Taxation has recently issued an ultimatum for Uber B.V Netherlands… – Continue reading
An agreement between Taiwan and the Czech Republic on double taxation avoidance and fiscal evasion prevention with respect to taxes on income was concluded Dec. 12 in Prague, setting the stage for increased investment and trade as well as industrial and technological cooperation between the two countries, according to the… – Continue reading
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
Hong Kong recently finalized a series of agreements that, taken together, shift Asia’s trade and investment landscape. On November 12, Hong Kong and ASEAN signed the ASEAN-Hong Kong, China Free Trade Agreement (AHKFTA), and the ASEAN-Hong Kong Investment Agreement (AHKIA). Prior to this, on November 10, Hong Kong and India… – Continue reading
Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading
The National Assembly endorsed the double taxation avoidance agreement between Bhutan and Bangladesh yesterday. Signed during the visit of Bangladesh Prime Minister Sheikh Hasina to Bhutan in April 2017, the agreement plans to do away with double taxation of incomes between the two countries. In the presence of 38 MPs,… – Continue reading
NAIROBI, Nov. 16 (Xinhua) — The East African Community (EAC) member states are set to ratify the avoidance of double taxation treaty in order to boost regional integration, a Kenyan official said on Thursday. Barrack Ndegwa, Regional Integration Secretary in the Ministry of EAC, Labor and Social Protection, told Xinhua… – Continue reading
The Ministry of Finance (Department of Revenue) vide notification S.O. 3512(E) dated November 2, 2017 sets out the Third Protocol to the Convention between the Government of the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with… – Continue reading
The Cabinet today gave its green light to an agreement between India and the Hong Kong Special Administrative Region (HKSAR) of China for avoiding double taxation and prevention of tax evasion. The Cabinet, chaired by Prime Minister Narendra Modi also approved the protocol amending the agreement between India and Kyrgyzstan… – Continue reading
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
Heads of the Armenian and Iranian tax entities met for the first time in Yerevan on Monday and expressed their willingness for deepening cooperation. The two sides also discussed updating the 1998 double taxation treaty. “It is time to edit the current agreement in line with the latest developments in… – Continue reading
In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading
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
PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading
Japan and Estonia signed a convention to eliminate double taxation on cross-border trade and investment on August 30. The treaty sets out the taxing rights of both countries on cross-border income deriving from investment or trade between the two. It also provides for assistance in the collection of tax and… – Continue reading
Croatia and New Zealand have agreed that they should negotiate an agreement on the avoidance of double taxation. Croatia’s President, Kolinda Grabar-Kitarovic, said an agreement was discussed in a meeting with New Zealand’s Prime Minister, Bill English, while she was on a state visit to the country. A double tax… – Continue reading
On 22 June 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on 13 October 2016. Currently, the ratification from Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the… – Continue reading
The Government of the Netherlands has announced that it has concluded an agreement with Indonesia on the taxation of investment funds. The Dutch Ministry of Finance announced on July 11 that the new competent authority agreement was signed by the two sides on June 23, 2017. The agreement clarifies the… – Continue reading
New Zealand has updated its double tax agreement with Hong Kong to allow for the automatic exchange of information in tax matters between the two jurisdictions. Once in force, the updated double tax treaty will require both Hong Kong and New Zealand to automatically exchange tax information with each other,… – Continue reading
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
Ghana and the Czech Republic have signed a Double Taxation Agreement. The Minister for Finance, Ken Ofori Atta, and the Czech Ambassador to Ghana, Margita Fuschova, signed on behalf of both countries. This agreement was signed after the two countries concluded negotiations for the Avoidance of Double Taxation and the… – Continue reading
The DTA clarifies the taxing rights on all forms of income flows arising from cross-border business activities and seeks to ensure such income is not taxed twice. The agreement provides that withholding taxes on dividends, interest, and royalties will generally not exceed seven percent. Withholding taxes on service fees will… – Continue reading
Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading
On 14 March 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg “On Avoidance of Double Taxation and Prevention of Income and Capital Tax Evasion” (the “Convention”) and a protocol to it (the “Protocol”). As we informed… – Continue reading
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
The Netherlands has signed a protocol to its double tax avoidance treaty with Uzbekistan, designed to prevent the treaty from being inappropriately used to avoid taxes. The anti-abuse provision was signed by the Netherlands and Uzbekistan on February 7, 2017, and “prevents the benefits of the treaty only [being] used… – Continue reading
Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
The signing of a double taxation agreement between the UK and the UAE in April 2016 was undoubtedly much anticipated and marks a new milestone in the successful expansion of the UAE’s international tax treaty network. Following ratification of the agreement by the two countries reacting parties, it came into… – Continue reading
