Malaysia uses both progressive and flat rates for personal income tax, depending on an individual’s duration and type of work in the country. As expatriates may fall into either tax category depending on their work, it is important to understand Malaysia’s basic tax structure. The Income Tax Act of 1967… – Continue reading
Cyprus and San Marino have signed a double taxation avoidance agreement. The agreement, which further enhances the relations between the two states, was signed between the Ministers of Foreign Affairs of Cyprus and San Marino, Ioannis Kasoulides and Nicola Renzi, who held a tete – a – tete meeting before… – Continue reading
The governments of Japan and Russia on April 28 announced they have agreed the text of a new double tax agreement that would replace the 1986 pact between Japan and the former USSR. In a statement following a visit by Japanese Prime Minister Shinzo Abe to Moscow, the Japanese Finance… – Continue reading
Luxembourg and Cyprus on Monday signed a bilateral convention for the elimination of double taxation. Luxembourg’s Finance Minister Pierre Gramegna was on a working visit in Nicosia and signed the convention with his Cypriot counterpart Harris Georgiades. Cyprus was the last EU member state not to have a tax convention… – Continue reading
Cyprus and Luxembourg, two of the EU`s financial centres, on Monday cautioned against the implementation of the proposed Common Consolidated Corporate Tax Base (CCTB) in the European Union. “Cyprus believes that we should be very cautious and very careful when it comes to corporate taxation,” Cypriot Finance Minister Harris Georgiades… – 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
It has been more than a year since the Australian government committed itself to remedying the nation’s double taxation scheme for cryptocurrencies. The delay in crafting a fix has left some observers wondering whether the issue had been set aside entirely. In a statement released this week, the government has… – 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
Pakistan and Bulgaria on Wednesday signed the Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income (ADTA) after the conclusion of second round of negotiations in Islamabad. The ceremony was overseen by Federal Board of Revenue Chairman Dr Muhammad Irshad and Bulgaria… – Continue reading
In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an… – Continue reading
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
LUSAKA – Zambia and Malawi have resolved to harmonise trade barriers that affect trade between the two neighbours through the signing of the Double Taxation Avoidance Agreement (DTAA). The DTAA, also referred to as a Tax Treaty, is a bilateral economic agreement between the two nations that aims to avoid… – Continue reading
NEW DELHI, APRIL 19: The Union Cabinet on Wednesday approved the signing of the Protocol amending the Convention between India and Portugal for avoidance of Double Taxation. According to an official statement, the Protocol will also ensure prevention of fiscal evasion with respect to taxes on income. The statement said,… – Continue reading
(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading
Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the… – Continue reading
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP… – Continue reading
Azerbaijan will sign agreements on elimination of double taxation with five more countries in the near future, Zaur Fetizade, head of Azerbaijani Taxes Ministry’s Department for International Cooperation and Tax Monitoring in Financial Institutions, said in his interview with the Vergiler (Taxes) newspaper. “We have already agreed on draft agreements… – Continue reading
Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading
The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading
For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although… – Continue reading
The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of… – Continue reading
The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – 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
ISLAMABAD: After Federal Minister for Finance Ishaq Dar took a ‘principled stand’, Pakistani and Swiss authorities are scheduled to ink a revised convention on avoidance of double taxation agreement today (Tuesday) here in the federal capital, enabling the Pakistani authorities to get information about dirty untaxed money of $200 billion… – Continue reading
MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning… – Continue reading
Recently,Ghana signed an agreement with the government of Mauritius to ensure that its investors will not be taxed twice by the two countries. Apart from that there are other countries that have such an agreement with Ghana. Ghana uses the instrumentality of Double Taxation Agreements (DTA) to rationalize the tax… – Continue reading
The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be… – Continue reading
Ghana has signed an agreement with the government of Mauritius to ensure that its investors will not be taxed twice by the two countries and vice-versa. Known as the Double Taxation Avoidance agreement (DTA), the both Foreign Affairs ministers Shirley Ayorkor Botchwey and Mauritius counterpart Hon SeetanahLutchmeenaraidoo signed the agreement… – Continue reading
New Delhi, March 9 (IANS) India and Belgium have signed a Protocol to amend the double taxation avoidance agreement to curb tax evasion, an official statement said on Thursday. “India and Belgium have signed a protocol amending the existing agreement and protocol between the two countries for avoidance of double… – Continue reading
Under increasing international pressure, the Hong Kong government is considering expanding its Automatic Exchange of Information (AEOI) implementation by imposing broader information collection obligations, entering into more bilateral AEOI agreements at a faster pace, and possibly joining the multilateral AEOI agreement. Background Hong Kong legislated to adopt the OECD Common… – Continue reading
The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading
The Swiss Federal Department of Finance has said that it is forging ahead with work on a new corporate tax proposal, named “tax proposal 17” (TP17). A steering committee held its first meeting on March 2. It is led by Federal Councillor Ueli Maurer and comprises members from the government… – Continue reading
Muscat: A portal for entities subjected to taxation was launched on Wednesday by the ministry of finance. The ministry, represented by the Secretariat General for Taxation launched the portal www.taxoman.gov.om. The portal has legislations, taxation charts and agreements on avoidance of double taxation as well as developments in the field… – Continue reading
The Government recently issued a resolution to ratify an agreement and a protocol on avoiding double taxation and preventing income tax evasion between Vietnam and the United States of America. The Ministry of Foreign Affairs was asked to complete necessary procedures in accordance with law. Meanwhile, the Ministry of Finance… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading
ABU DHABI, 16th February, 2017 (WAM)–The Ministry of Finance, MoF, has signed two final agreements on the avoidance of double taxation and the protection and promotion of investment with Burundi. The agreements came as part of the Ministry’s strategy to expand its international relations and to protect and promote Emirati… – Continue reading
ISLAMABAD-Pakistan and Hong Kong on Friday signed the pact on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income. Pakistan’s Ambassador to China Masood Khalid signed the agreement while the Secretary for Financial Services and the Treasury, Professor KC Chan signed on behalf of… – Continue reading
Azerbaijan and Denmark have signed the convention on avoidance of double taxation and prevention of tax evasion on income taxes. The document was signed by Azerbaijani Minister of Taxes Fazil Mammadov and his Danish counterpart Karsten Lauritzen. Mr. Mammadov said that the document will contribute to the development of trade… – Continue reading
On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article 269 of the Tax Code of the Russian Federation (the “Review”). There is no… – 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
A prominent QC yesterday backed calls for the Bahamas to switch to a ‘low tax’ business model, warning: “The survival of financial services is not an option.” Brian Moree QC, senior partner at McKinney, Bancroft & Hughes, said the Bahamas had to “figure out how to adjust its business model”… – Continue reading
Proposed changes to Switzerland’s corporate tax framework have been rejected in a referendum. Provisional results show that the Corporate Tax Reform III (CTR III) package was opposed by just over 59 percent of voters in the February 12 referendum. CTR III would have abolished corporate tax arrangements that the Swiss… – Continue reading
The Airline Operators of Nigeria (AON) has blamed the poor performance of domestic airlines on multiple taxation by various agencies in the aviation sector. Capt. Nogie Meggisson, Chairman, AON, made the claim on Sunday in Lagos while reacting to the takeover of Arik Air and Aero Contractors by the Asset… – Continue reading
YEREVAN, February 9. /ARKA/. The Armenian parliament ratified today an agreement between the governments of Armenia and Argentina on exchange of taxation-related information, signed in 2015 July. According to the deputy head of Armenian State Revenue Committee Vakhtang Mirumyan, this agreement, initiated by the Argentine side, is aimed at providing… – Continue reading
For avoiding double taxation and for the prevention of fiscal evasion with respect to taxes on income, India and Austria signed a protocol, amending the existing convention between the two countries. On behalf of India, the protocol was signed by the Chairman of CBDT, Shri Sushil Chandra, and on behalf… – 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
India has revised 40 treaties for avoidance of double taxation so that the information exchanged with partner nations on tax matters can also be utilised for other purposes including criminal proceedings, Parliament was informed on Friday. “Treaty partner countries have been requested to modify the tax treaties, so as to… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended… – Continue reading
