Category: Double Taxation

Taxmen mishandled Swiss treaty talks in 2014

ISLAMABAD: Pakistan’s hopes to seek information from Switzerland about the presumed $200 billion stashed in Swiss banks have apparently been ruined by tax authorities who mishandled delicate negotiations for amending a convention on avoidance of double taxation. A Pakistani delegation that visited Switzerland in August 2014 to renegotiate the 2005 treaty… – Continue reading

China: Attention to Five Changes for Application of Bilateral Tax Agreement

Range Extension Public Notice [2015] No. 60 provides non-resident taxpayers enjoying bilateral tax agreement and the international transport agreement with applicable unified, standardized management processes. Specific changes include: signed agreements for the avoidance of double taxation signed tax provisions of airlines, shipping and car services, tax agreement for the mutual… – Continue reading

Inland Revenue (Amendment) Bill 2016 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) Bill 2016 was gazetted today (January 8). “The Bill seeks to put in place a legal framework for Hong Kong to implement the new international standard for automatic exchange of financial account information in tax matters (AEOI) as promulgated by the Organisation… – Continue reading

The Implications of BEPS for CEOs and Boards

On October 5, the OECD issued it formal recommendations on the Base Erosion and Profit Shifting (BEPS) Action Plan. These recommendations have been subsequently adopted by the G20. We acknowledge the monumental effort that has been put forth to produce a modernized international system of tax rules through the BEPS… – Continue reading

President optimistic about future for Taiwan’s next generation

Taipei, Jan. 6 (CNA) President Ma Ying-jeou (馬英九) lauded his administration’s efforts to improve the country’s development and expressed optimism Wednesday about the future for Taiwan’s next generation, citing a recent survey that found Taiwan the most optimistic about the future among other Asian nations. If peace and prosperity in… – Continue reading

European Union: Implementing The Revised Parent Subsidiary Directive Across The EU

A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading

Cyprus: Taxation – Amendments On The Double Tax Treaty Between The Republic Of Cyprus And Ukraine

Representatives of the Cyprus and the Ukrainian governments have signed, in Kiev, on Friday, 11 December 2015, a protocol amending their Double Tax Avoidance Treaty. The protocol is based on the Model Tax Convention for the Avoidance of Double Taxation OECD. The changes need to be ratified by both the… – Continue reading

INVESTMENT IN DUBAI’S REAL ESTATE BUSINESS

This is apropos a Business Recorder news item ‘Investment in Dubai real estate: NAB asks FBR to verify claims of Transparency International-Pakistan ‘. According to the report, the National Accountability Bureau (NAB) has asked the Federal Board of Revenue (FBR) to verify claims of Transparency International-Pakistan on a huge investment… – Continue reading

Georgia avoids double taxation with Iceland

Georgia and Iceland are stepping up their bilateral cooperation in taxation and customs affairs. Today a cooperation agreement on avoidance of double taxation, prevention of evasion of income and capital taxes, came into force. The agreement initially was signed in May this year when Finance Ministers of Cyprus, Liechtenstein and… – Continue reading

Multinational conglomerates escape transfer-pricing charge

VietNamNet Bridge – The agreements on double taxation avoidance that Vietnam has signed with other countries is one of the reasons that have made it impossible for state agencies to clarify the suspected cases of multinational conglomerates conducting transfer pricing. A lot of multinational conglomerates such as Coca-Cola, Metro Cash… – Continue reading

Centre clears tax, info exchange pacts with Maldives, Slovenia

In order to exchange information aimed at curbing tax evasion and avoidance, Union Cabinet chaired by the Prime Minister Narendra Modi approved the signing and ratification of an agreement between India and Maldives. The Agreement will stimulate effective exchange of information between the two countries which will help curb tax… – Continue reading

New Luxembourg-Singapore agreement for the avoidance of double taxation which will stimulate trade and investment flows between both jurisdictions enters into force

On 28 December 2015, the revised Luxembourg-Singapore Agreement for the Avoidance of Double Taxation (the New Treaty) entered into force. The New Treaty (1) allows Luxembourg investment vehicles to invoke benefits under the New Treaty, (2) reduces the withholding tax rates for dividends, interest and royalties, (3) increases thresholds to… – Continue reading

Indian companies with foreign units likely to be impacted by POEM guidelines

MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading

B&E | Measures to Control the Abuse of Offshore Tax Havens

“Cash Booked Offshore for Tax Purposes by U.S. Multinationals Doubled between 2008 and 2014” In recent years, U.S. multinational companies have sharply increased the amount of money that they book to foreign subsidiaries. An April 2015 study by research firm Audit Analytics found that the Russell 1000 list of U.S…. – Continue reading

Algeria: President Bouteflika Inks Presidential Decrees Ratifying Many Agreements

Algiers — President of the Republic Abdelaziz Bouteflika signed presidential decrees on the ratification of many cooperation agreements between Algeria and other States and international organizations, in accordance with Article 77-11 of the Constitution, said Sunday the Presidency of the Republic in a statement. One of the decrees concerns the… – Continue reading

BEPS Action Plan 2: Neutralizing the effects of hybrid mismatch arrangements

Hybrid mismatch arrangements are the focus of the 2-part Action Plan 2 of the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) initiative. Hybrid Mismatch Arrangements abuse differences in the tax treatment of an instrument (i.e., a hybrid instrument) or an entity (i.e., a hybrid… – Continue reading

Singaporean – Ecuadorian DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Ecuador for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Singaporean – San Marinese DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of San Marino for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Singaporean – Seychellois DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

MoU signed with BD, Bahrain

Bangladesh and Bahrain have signed three instruments in Manama to further strengthen cooperation in various fields between the two countries. The instruments are Agreement on the Reciprocal Protection and Promotion of Investment, Agreement on the Avoidance of Double Taxation and a MoU on Foreign Office Consultations. The first two instruments… – Continue reading

Ministry of Finance hosts Ethiopian delegation

Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received a delegation from Ethiopia at the Ministry of Finance headquarters in Abu Dhabi. The meeting was held to discuss investment opportunities and economic cooperation between UAE and Ethiopia. The agreement on the avoidance of double taxation on income signed… – Continue reading

Qatar’s National Day Observed

The embassy of the State of Qatar in Banjul were on Saturday, December 19th joined by Gambians in celebrating the oil-rich Gulf country’s National Day. Senior government officials including cabinet ministers, as well as foreign diplomats and representatives of various agencies in The Gambia graced the event. Speaking at the… – Continue reading

BOTSWANA, African tax haven?

About Botswana Botswana, a former British colony in Southern Africa, is one of the most prominent countries in Africa. The country has a strong economy,uses one of the most advanced banking systems in the continent, and maintains a stable tradition of representative democracy. After becoming independent in 1966, Botswana developed… – Continue reading

Arab League intent on increasing investments in Brazil

The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading

Relocating Canadian employees to the US: Three major tax considerations

Employees relocating from Canada to the US may face a number of complex tax-related issues. Matt C Altro, president and CEO of Canadian firm MCA Cross Border Advisors, shares his advice for companies and their relocatees on planning for, and coping with, these challenges. Talent mobility is a key issue… – Continue reading

The deal between Turkey and FATCA

Turkey’s ruling Justice and Development Party (AKP) government, in power for 13 years, has been notoriously lax and often late when it comes to implementing stringent rules controlling money in order to ensure better transparency in financial movements, halt tax evasion, prevent illicit funding and disrupt money laundering activities. That… – Continue reading

Financial Information Sharing for 2016

Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading

Financial Information Sharing for 2016

Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading

Battle of words over taxation

On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading

Luxembourg – Main New 2016 Tax Measures At A Glance

IP regime  To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading

‘Tax rules worsen business climate’

ISLAMABAD: The World Bank says tax regulations in Pakistan are frequently altered, and unpredictable tax rules worsen the business climate and may deter potential investment. The report “Towards a more friendly tax regime: Key challenges in South Asia,” points out that South Asia’s tax regulations are complex and difficult to… – Continue reading

Brazil’s Superior Court of Justice issues decision exempting payments of services to Spain from withholding tax in Brazil

In the context of a series of recent developments on the tax treatment of cross border services payments from Brazil, the Superior Court of Justice (STJ) recently ruled that payments for services performed by a Spanish company without permanent establishment in Brazil are not subject to withholding income tax in… – Continue reading

Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud

Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading

EC Extends Investigation Into Apple Tax Deal

The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading

Double taxation avoidance

India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading

IP BOX: Italian and European Legal Framework

On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading

Latvian president calls for double taxation treaty with Japan

Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading

British Virgin Islands: What Structure Should I Use For My Offshore Fund?

There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading

DYK: Dividend from investing in shares of foreign companies is taxable in India

Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading