Category: Double Taxation

Ethiopia, Switzerland keen to bolster ties

Ethiopia and Switzerland have expressed their commitment to strengthen bilateral relations covering various regional and global issues of common interest, according to a joint statement issued on Tuesday by the two countries.The communiqué was released after talks between Swiss President Simonetta Sommaruga and Ethiopian Prime Minister, Hailemariam Desalegn, on Tuesday… – Continue reading

Iranian ambassador takes office in Uzbekistan

Uzbekistan’s Foreign Minister Abdulaziz Kamilov received the copies of credentials of Iran’s new Extraordinary and Plenipotentiary Ambassador Bahman Agharazi Dormani, Uzbek Foreign Ministry said. During the meeting, the sides discussed the status and priority areas of Uzbek-Iranian cooperation in political, trade, economic, cultural, humanitarian and other spheres. They reiterated mutual… – Continue reading

Japan will start using electronic ID card following the Estonia

Prime Minister of Estonia Taavi Rõivas met on Friday with Japanese Economy Minister Akira Amari who came to visit Estonia to study Estonia’s e-services and they discussed the two countries closer trade relations and the development of the digital society, the government’s communication unit reports BC. Japan is the first… – Continue reading

Expo 2020 will bring world to Dubai to learn and share ideas: Mohammed

His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, today received at Zabeel Palace, Nikola Gruevski, Prime Minister of Macedonia, and his accompanying delegation. At the beginning of the meeting, which was attended by Sheikh Maktoum bin Mohammed bin Rashid… – Continue reading

Brazil: GSGA – Special Report – Brazilian Tax Review 03/2014 – April/May/June

Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading

DTAA tackles double taxation of job income

Expansion activities of companies lead to relocation of their employees to different territories, even outside the country. It goes without saying that transfer in job from one location to another comes with a baggage of issues, including the taxability of income from employment. The tax matter needs particular attention if… – Continue reading

Procurement Services by Chinese Company Taxable as Fees for Technical Services under India-China Tax Treaty: AAR

• There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. • The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even… – Continue reading

East Africa: Rwanda Taxman Moves to Catch Tax Evaders

Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading

UK: Data, Privacy And Taxation – A Very Modern Conflict

Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading

Taiwan and Mainland China signed a Cross-Straits Income Tax Agreement

Taiwan and Mainland China signed the “Cross-straits Agreements for the Avoidance of Double Taxation on Income and Solidifying Cooperation with respect to Taxes” (hereinafter referred to as “Cross-straits ITA”) on 25 August 2015. After the draft Article 25-2 of the “Act Governing Relations between the People of the Taiwan Area… – Continue reading

As Maruti and HUL show, royalty is a small price to pay

While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading

Govt Drops Double Taxation Rule for REITs

Jakarta. The Indonesian government revealed its fifth stimulus package on Thursday in a bid to prop up the economy by, among others, scrapping double taxation imposed on companies called real estate investment trusts to improve property investment. The package was announced by Cabinet Secretary Pramono Anung, Coordinating Minister for Maritime… – Continue reading

Shell companies’ patents to come under domestic tax net on adoption of BEPS

MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading

India: Foreign Tax Credits Available For Exempt Indian Income: Karnataka High Court

Foreign tax credit available to taxpayers even on a portion of exempt income. Exempt income (under section 10A) is chargeable to tax under section 4 and 5 of the ITA although no tax may actually be payable. Actual payment of the tax is not necessary for claiming foreign tax credits…. – Continue reading

MNCs in India may find it difficult to dodge taxmen

Multinational companies (MNCs) in India which have been evading tax on profits created due to a function carried out in the country by shifting contractual risk to some other location may soon find it difficult to escape the domestic tax net. Experts closely working with the government on how to… – Continue reading

Agreements with Italy and Japan to avoid international double taxation

The negotiations conducted by the Ministry of Finance and the Internal Revenue Service (SII) for Chile to sign the agreements to avoid international double taxation with Italy and Japan have concluded successfully. “The successful completion of negotiations with two of the world’s major economies crown an exceptional year in strengthening… – Continue reading

Mauritius eyes Africa as pressure mounts on offshore business

Mauritius beats Singapore as the world’s top route for foreign investment to India and is a hub for thousands of firms managing half a trillion dollars in assets. But there are only a sprinkling of office blocks in Ebene Cybercity, the heart of the tiny Indian Ocean island’s financial services… – Continue reading

Tax Justice for Social Justice

By Martina Neuwirth and Thomas Kattnig [This blog article published on July 9, 2015 is translated from the German on the Internet, http://blog.arbeit-wirtschaft.at.] June 23 was the international day of public services. Did you know that? Provision of these services – water, hospitals, schools, culture, energy, streets, public transportation and… – Continue reading

UAE and Mauritania sign agreements on preventing double taxation and boosting investment

NOUAKCHOTT 22nd October 2015 (WAM) — The UAE and Mauritania yesterday signed two agreements preventing double taxation and protecting and promoting investment between the two countries. The agreements were signed by H.H. Sheikh Abdullah bin Zayed Al Nahyan Foreign Minister and Hamadi Ould Baba Ould Hamadi Mauritanian Minister for Foreign… – Continue reading

Carl Icahn Forms Super PAC Aimed At Tax Reform

Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading

Worldwide: OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading

Execs Weigh Impact of OECD BEPS Impact on U.S. Tax Reform

The impact of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is still unclear, but tax executives are planning ahead for changes on the international tax front. Earlier this month, the OECD unveiled its plan for combating tax evasion strategies by multinational corporations (see… – Continue reading

Latin Stars’ Concert Fees Investigated for Possible Fraud: Report

Panamanian officials question declared payments for Enrique Iglesias, Julio Iglesias, Alejandro Sanz and other artists Enrique Iglesias, Alejandro Sanz and Julio Iglesias are among the artists named in an investigation by Panamanian tax authorities into possible tax evasion, concerning money they received for concerts in that country. According to an… – Continue reading

Foreign portfolio investors seek stable tax policies to set up fund management businesses

NEW DELHI: Foreign portfolio investors have sought stability in taxation policies as the government looks to lure them to set up fund management business in the country. They have made a number of suggestions, Economic Affairs Secretary Shaktikanta Das said after a meeting of the finance ministry with representatives of… – Continue reading

Treasury offers tax deduction to SA firms in Africa

SOUTH African companies with operations elsewhere in Africa, such as telecommunications giant MTN, have reason to breathe a little easier having earned a tax respite, albeit considered minor by tax experts. The Treasury has made a concession on the proposed repeal of foreign tax credits for fees on services provided… – Continue reading

The OECD/G20 base erosion and profit shifting (BEPS) project – an informed perspective

The BEPS Project involves input from the 34 member countries of the OECD, all G20 members, and more than 40 developing countries. The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that… – Continue reading

New tax treaty between the Netherlands and Curaçao enters into force

Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading

Mauritius Wants To Be To Africa What Dubai Is To The Middle East

Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading

MTN bullies SA with jobs threat

South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading

Hong Kong’s tax co-operation status clarified by EC

Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading

Ireland translates aviation success to ship leasing according to new report

Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading

PANAMA: REVISED GUIDANCE, APPLICATIONS FOR RULINGS FOR TAX TREATY BENEFITS

A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading

Real estate, the golden visa and tax

Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading

Belarus-Georgia agreement on avoidance of double taxation ratified

MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading

Dutch Tax Bill 2016: what will change?

The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading

HMRC prevails in trial against £200m double taxation loophole

HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading

The Algeria and the United States sign an agreement on sharing tax information

The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading

Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading

ANCA Welcomes Congressman Ted Lieu’s Advocacy for a U.S.-Armenia Double Tax Treaty

LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading