India and the U.S. have reached an agreement to resolve more than 100 pending transfer pricing cases, one of the biggest deterrents for foreign investors planning an India foray, according to a government statement. Some more are expected to be resolved soon. Transfer pricing refers to the setting of the… – Continue reading
2015 has officially come to an end. Amidst the ending celebrations, packing away of decorations, and last spoonful of dessert, many of us are putting together our work plans and resolutions for 2016. And looking back at last years’ list, there remains one capitalised, un-crossed-off item: BEPS Perhaps your organisation… – Continue reading
The Ministry of Finance is planning to make the forthcoming general budget people-friendly. According to informed sources, the service tax exemption limit is expected to be increased from Rs 10 lakh at present to Rs 25 lakh. This is being seen as a major step aimed at benefitting traders and… – Continue reading
Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading
NEW DELHI: The Central Board of Direct Taxes (CBDT) today said it has resolved as many as 100 transfer pricing disputes with the US, which will lead to an environment of “tax certainty and encourage MNCs” to do business in India. The resolution of such issues, CBDT said further, follows… – Continue reading
Lawmaker says show of support from KC leaders had an impact KANSAS CITY, Mo. —A Missouri bill aimed at abolishing the earnings taxes in Kansas City and St. Louis is changing. As KMBC 9 News first reported Wednesday night, a new version of the bill will no longer include Kansas… – Continue reading
BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading
On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading
India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading
NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading
NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading
Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading
South Korea and the Republic of Serbia have signed an agreement on the prevention of double taxation. South Korea’s Ambassador to Serbia Lee Do-hoon said that Serbian Finance Minister Dusan Vujovic and he signed the agreement on Friday in Serbia. South Korea’s Foreign Ministry expects the latest taxation agreement will… – Continue reading
The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading
The good news: Indonesia to scrap the recently announced 10pc tax on cattle sales. The bad news: Unless permit dispensations are secured soon, there will be no cattle exports from Australia to Indonesia in April. The 10 percent Value-Added Tax (VAT) introduced on cattle sales in Indonesia earlier this month… – Continue reading
Study abroad programmes will be exempt from a new 25% tax on overseas payments that was announced last week, the Department of Federal Revenue has announced, prompting a sigh of relief among stakeholders that send and receive Brazilian students abroad. The new levy prompted widespread concern in the study abroad… – Continue reading
KARACHI: The Federal Board of Revenue (FBR) has issued a detailed clarification, which clearly defines that the federal government is authorised to levy sales tax on supply and manufacturing of goods, whereas the power to levy sales tax on services have been vested with provinces. The clarification was made in… – Continue reading
Generally, if a South African taxpayer sells shares in a foreign company, he will be hit with South African capital gains tax (CGT) on any gain realised on that sale. However, South Africa provides exemptions from this CGT in certain circumstances, one of which relates to the sale of foreign… – Continue reading
In response to contentions expressed over double taxation by a KCCI delegation during its recent meeting with Chairman FBR, the Federal Board of Revenue (FBR) has issued a detailed clarification which clearly defines that the federal government is authorised to levy sales tax on supply and manufacturing of goods whereas… – Continue reading
India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading
As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading
Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. Unfortunately, these calls are based on outdated numbers and an incomplete picture of the tax system…. – Continue reading
The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading
WASHINGTON, D.C.—Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. A few weeks ago, the IRS released new data showing that the average federal individual… – Continue reading
Hong Kong’s newly signed double tax deal with Russia is said to support the territory’s ongoing efforts to expand its tax treaty network with jurisdictions along “the Belt and Road.” The Belt and Road, or the Silk Road Economic Belt, is a Chinese Government economic development project, which is primarily… – Continue reading
European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading
Danish Tax Minister Karsten Lauritzen has created a new government-industry task force that will support the Government to broaden and improve Denmark’s network of double tax agreements. According to a Tax Ministry statement, the task force will enable the Government to listen to the opinions of businesses when deciding on… – Continue reading
Each year, states enact tax law changes and create local government programs that provide personal property tax breaks for businesses. These concessions come in various forms—deductions, incentives, credits and exemptions (i.e., D.I.C.E.), and they have a significant impact on whether businesses remain viable. Many states commonly impose ad valorem tax… – Continue reading
In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading
The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading
What is the fate of taxpayers on double taxation provisions? The National Tax Policy (NTP) acknowledges this challenge when it states, “elimination of multiple taxation must be of major concern to government at all levels. This is because increased demand to grow internally generated revenue has led to the exercise… – Continue reading
As part of the ongoing visit by President Muhammadu Buhari to the United Arab Emirates (UAE), both countries today signed six agreements on Trade, Finance and Judicial Matters; Avoidance of Double Taxation; Trade Promotion and Protection; Judicial Agreements on Extradition, Transfer of Sentenced Persons; Mutual Legal Assistance on Criminal Matters;… – Continue reading
Three leading cellular operators have made a joint representation to the Federal Board of Revenue (FBR) that the scheme of taxation contemplated by the Ninth Schedule of the Sales Tax Act 1990 in relation to both items – SIM cards and handsets – is legally impermissible and unconstitutional and practically… – Continue reading
Russia and the Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on avoidance of double taxation and prevention of fiscal evasion regarding profits taxes on Monday. The document was signed by Russia’s State Secretary, Deputy Finance Minister Yuriy Zubarev and the Secretary for Financial… – Continue reading
The change in definition of an Indian resident company under the Income-Tax Act—from one whose affairs are wholly controlled and managed in India to one whose Place of Effective Management (PoEM) is in India—and the subsequent draft guidelines are giving anxious moments to votaries of simplifying the investment climate in… – Continue reading
The Cellular Operators’ Association of India (COAI) has submitted a budget recommendations to the government which include suggestions on central value added tax (CENVAT) Credit, deductibility of spectrum fees paid and tax withholding on distributors margin on sale of SIM cards and prepaid vouchers among many others. The recommendations said… – Continue reading
A double taxation avoidance agreement between Taiwan and Canada was concluded Jan. 15 in Taipei City, paving the way for expanded exchanges in clean energy, health care, sustainable development, services and technology. Set to take effect Jan. 1, 2017, the pact prevents the levying of tax by both sides on… – Continue reading
JEDDAH: Saudi Arabia has maintained third in the global ranking for ease of tax payment, according to the latest release of the Paying Taxes report by the World Bank and PwC. With the least demanding tax framework, well below the world average, the Kingdom has a total tax rate of… – Continue reading
Taipei, Jan. 15 (CNA) Taiwan and Canada have signed an agreement to prevent the taxation of the same income twice in the two countries, the Ministry of Foreign Affairs said Friday. The signing was completed earlier in the day and will likely take effect on Jan. 1, 2017 after the… – Continue reading
CROWN POINT — Lake County officials are debating whether they have accidentally double taxed Cedar Lake and Schererville residents. Lake County Commissioner Gerry Scheub, D-Crown Point, argues this week a mistake by the County Council in funding the county’s E-911 public safety dispatching service has resulted in Cedar Lake residents… – Continue reading
NEW DELHI:The Narendra Modi government, which has pledged a predictable and non-adversarial tax regime, is likely to begin a sweeping revamp of direct taxes in the Budget that Finance Minister Arun Jaitley will present next month. Simplification and rationalisation will be the two themes driving the overhaul, which is aimed… – Continue reading
Majlis (Parliament) of Turkmenistan has ratified an agreement with the government of Finland for the avoidance of double taxation with respect to taxes on income during the regular meeting, the Turkmen government said Jan.13. Turkmenistan believes that namely innovations ensured Finland’s competitiveness at international level. The message of the State… – Continue reading
Tax inversions and corporate tax rate cuts would be huge for these stocks Certain politicians are decrying a tax move known as an “inversions,” which allow a U.S. company to merge with a foreign one with a more favorable tax rate. Yet, it’s the politicians who created the necessity for… – Continue reading
The jury is out on whether a group helmed by President Joko Widodo can revive stalled growth in Indonesia’s Islamic finance industry. The head of the world’s biggest Muslim population is chairing a new committee tasked with bringing fragmented regulations under one roof and taking action to spur the market,… – Continue reading
AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading
As part of the ATO’s reinvention agenda we have been reviewing our Advance pricing arrangement (APA), Mutual agreement procedure (MAP) programs and our Competent Authority Network to identify opportunities to: improve the client experience and better support willing participation improve our bilateral and multilateral engagement increase our efficiency and effectiveness…. – Continue reading
HAVE YOU worked on an overseas project for a Thai employer where you’ve had to stay in an overseas assignment for 183 days or more in a year or over two consecutive years? If so, how should you handle any double taxation? While it’s important to pay tax correctly, you… – Continue reading
This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading
NAIROBI, Jan. 11 (Xinhua) — Kenya and Canada are set to sign an agreement on the promotion of investments and trade between the two countries, officials said on Monday. Canadian High Commissioner to Kenya David Angell told Xinhua in Nairobi that the two governments are talking to each other and… – Continue reading
The European Union ordered Belgium to recover about 700 million euros ($762 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev NVand BP Plc, as regulators continued a crackdown on overly generous tax schemes throughout the 28-nation bloc. The European Commission told Belgium to recoup… – Continue reading
