Category: Double Taxation

Ireland: Private Client Tax Ireland

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading

India Unties $6.4 Billion Tax Knot That Rattled Investors

India said foreign portfolio investors can use tax treaties to reject demands on past capital gains, seeking to defuse a row that cast a cloud over the $48 billion poured into stocks and bonds from overseas. Foreign institutional investors domiciled in countries that have signed double taxation avoidance treaties with… – Continue reading

Malta: Business, Investments And Residency Opportunities!

TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading

S’pore, Mauritius FIIs still out of MAT net: Dinesh Kanabar

Dinesh Kanabar, CEO, Dhruva Advisors explains that there are three kinds of FIIs: protected by double taxation avoidance treaty, no treaty but physical presence in India, and no treaty and no presence in India. So far notices have been sent only to the second category of investors. Minimum alternate tax… – Continue reading

New Agreement between Bulgaria and Romania for the avoidance of double taxation will stimulate bilateral business relations

Sofia. The Bulgarian government approved a draft of a new agreement between Bulgaria and Romania for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income. The document will be signed in case of following ratification. That is what the government information service announced…. – Continue reading

Why Finance Minister Arun Jaitley is Pranab Mukherjee 2.0 for the markets

The Finance Minister has failed to assuage markets’ fears on the issue of retrospective tax Markets are getting jittery each time the finance minister or his ministry utters the T word. Finance Minister Arun Jaitley reminds the market of UPA’s finance minister Pranab Mukherjee, who introduced the now-dreaded retrospective tax…. – Continue reading

China beefs up tax services to spur investment in Belt and Road

BEIJING, April 20 (Xinhua) — China’s taxation authority unveiled ten measures on Monday to improve taxation services for investors to serve the Belt and Road Initiative. The measures will protect investors’ interests, promote development and achieve a win-win outcome, said the State Administration of Taxation (SAT). Tax guides will be… – Continue reading

Global Law Experts distinguishes GRP Rainer Lawyers and Tax Advisors as a leading law firm in the field of tax law

The internationally recognized handbook for legal experts Global Law Experts has distinguished GRP Rainer Lawyers and Tax Advisors as one of the leading law firms in the field of tax law. GRP Rainer Lawyers and Tax Advisors in Cologne, Berlin, Bonn, Düsseldorf, Frankfurt, Hamburg, Munich, Stuttgart and London has been… – Continue reading

OECD MAP Statistics Show Pressing Need for Mandatory Binding Arbitration

The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading

Taxpayer Advocate Recommends Merging FATCA and FBAR Reporting Rules

The National Taxpayer Advocate has recommended that the reporting rules under the Foreign Account Tax Compliance Act and for foreign bank account reports in effect be merged to simplify the duplicative disclosure requirements that make it difficult for American expatriates to have bank accounts in the foreign countries where they… – Continue reading

‘Constructive’ talks on US banks tax evasion row

Tensions between Swiss banks and the United States justice authorities should ease up in 2015, Finance Minister Eveline Widmer-Schlumpf has said on the sidelines of the joint International Monetary Fund and World Bank spring meetings in Washington. The minister said she had received positive signals that this year would bring… – Continue reading

First Germany, now UK objects to India ‘breach’ of secret bank data

The United Kingdom (UK) has followed Germany in lodging a formal protest with the Finance Ministry over the alleged breach of confidentiality of data and secret banking details received via diplomatic channels. While German authorities objected to the manner in which 18 names of Indian account holders in the LGT… – Continue reading

China helps Indonesia track $500 million of ill-gotten assets

Chinese authorities will cooperate with Indonesia to confiscate more than $500 million of ill-gotten assets illegally transferred to China by corrupt Indonesian banking officials. Under the Treaty on Mutual Legal Assistance in Criminal Matters between China and Indonesia that took effect in 2006, the Ministry of Justice will “give support… – Continue reading

Dixcart Releases Guide On UK’s Diverted Profits Tax

Dixcart, an international business support services provider, has released a new guide on the UK’s Diverted Profits Tax, which was altered ahead of its introduction on April 1, 2015. The DPT is intended to counter aggressive tax avoidance by multinational companies. It is charged at a rate of 25 percent… – Continue reading

Saudi tax deal heralds increased efforts to boost trade, investment

Portugal’s deputy prime minister, Paulo Portas, and Saudi Arabia’s minister of trade, Tawfiq bin Fawzan Al-Rabiah, recently signed an agreement abolishing double taxation between the two countries, as part of a continued broader effort by Portugal’s government to boost exports and investment. The document was signed after a meeting in… – Continue reading

Fijian Attorney-General Receives Sultanate OF Oman Ambassador to Fiji

The Attorney-General, Hon. Aiyaz Sayed-Khaiyum today received the new non-resident Ambassador of the Sultanate of Oman to Fiji, His Excellency Nazar Al-Said. In welcoming the Omani envoy to Fiji, Minister Sayed-Khaiyum said that the Fijian Government looked forward to developing its bilateral relations with Oman, particularly in the areas of… – Continue reading

Manufacturing Groups Call For Corporate Tax Overhaul

Ahead of this week’s income tax filing deadline, the National Association of Manufacturers and the Manufacturers Alliance for Productivity and Innovation Foundation said the U.S. should exempt its companies’ foreign earnings from corporate taxes. In contrast to current tax policy, the groups’ analysis argued that exempting those earnings would allow… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading

UAE MoF and UAQ FTZ sign MoU on international OECD tax regulations

The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading

Royalty, technical fee: PJBF asks FBR to de-notify FED levy

Pakistan-Japan Business Forum has recommended to the Federal Board of Revenue (FBR) to immediately de-notify Federal Excise Duty (FED) on royalty and technical fee, which is now chargeable under the provincial legislation promulgated in Sindh, Punjab and KP, as sales tax on services. Sources told Business Recorder on Saturday that… – Continue reading

Royalty, technical fee: PJBF asks FBR to de-notify FED levy

Pakistan-Japan Business Forum has recommended to the Federal Board of Revenue (FBR) to immediately de-notify Federal Excise Duty (FED) on royalty and technical fee, which is now chargeable under the provincial legislation promulgated in Sindh, Punjab and KP, as sales tax on services. Sources told Business Recorder on Saturday that… – Continue reading

Australian trade minister: FTA with GCC ‘possible within months’

Australia and the GCC countries may only be a few months away from signing a landmark Free Trade Agreement (FTA) deal “if a decision is made quickly,” with such a deal having multiple benefits for various Gulf-based businesses and stakeholders, said Australia Trade and Investment Minister Andrew Robb. Speaking to… – Continue reading

Government to review gas producers’ taxation – draft budget resolution for 2016

The Ukrainian government will review the system of taxation of gas production companies irrespective of their form of ownership. This is stipulated in the draft guidelines of Ukraine’s budget policy, or the budget resolution, for 2016, which was tabled by the Cabinet of Ministers in parliament. Among the other priorities… – Continue reading

Experts warn over tax devolution

Scottish Government must work closely with councils to ensure devolution of taxation powers to Scotland brings tax and welfare systems together, according to experts. The Chartered Institute of Taxation (CIOT) also warned draft legislation could have ‘unintended complexities’, leading to double taxation on foreign income and forcing more Scottish taxpayers… – Continue reading

Switzerland: Tax Briefing – Switzerland Takes Next Steps Towards Automatic Exchange Of Information In Tax Matters (AIA)

1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading

Tax Treaty Changes Boost HK-Shanghai Stock Trading

Hong Kong Exchanges and Clearing Limited’s securities market turnover has risen to a record high, and the recent signing of the fourth Protocol to the China-Hong Kong double taxation agreement (DTA) will further boost trading activity through the Shanghai-Hong Kong Stock Connect (SHKSC) program. Hong Kong Exchanges and Clearing Limited’s… – Continue reading

Tourism, rise in Thai govt spending set to drive economic growth

BANGKOK: — IN SPITE of global economic sluggishness dampening overseas shipments this year, the Thai economy should grow more strongly during the current quarter, driven by tourism growth, rising government spending and recovering exports, ministers said yesterday. At the annual meeting of the Thai National Shippers Council, Deputy Prime Minister… – Continue reading

Cheers greet proposed changes for managed investment trusts

Proposed changes to Australia’s managed investment trust regime have been met with cheers from the investment community as they welcome the boost in certainty and tax treatments. The government revealed the long-awaited changes to Australia’s MIT tax system on Tuesday, and expects to create a new standalone regime that will… – Continue reading

China’s pre-emptive strike on OECD profit-shifting initiative

China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading

AM 2015-01—does previously taxed income “tier up” to a domestic corporate shareholder?

Introduction In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an amount in income under subpart F, does the subpart F inclusion increase the corporate shareholder’s “earnings and profits” immediately or only when the earnings are actually… – Continue reading