Category: Double Taxation

Multinationals still able to use ‘double Irish’ tax arrangement after 2020

Multinational companies will still be able to use the controversial “double Irish” tax arrangement after the final end date of 2020, Sinn Féin MEP Matt Carthy has said. A number of tax experts have confirmed this is the case, though they have disputed whether the terms of which they will… – Continue reading

Nearly 100 Countries Poised to Adopt Multilateral Treaty

Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading

UK, Colombia In Double Tax Deal

The UK and Colombia signed a double tax agreement (DTA) on November 2, which is intended to support trade and investment by capping withholding tax on cross-border income. The agreement was signed by the Financial Secretary to the Treasury, Jane Ellison, and the Colombian Finance Minister, Mauricio Cardenas, during President… – Continue reading

UAE, Argentina sign deal on double taxation

The UAE has signed an agreement on the avoidance of double taxation with Argentina with the aim of boosting expanding joint economic partnerships. The agreement was signed by Obaid Humaid Al Tayer, Minister of State for Financial Affairs, and visiting Argentina’s Vice President Gabriela Michetti, in the presence of Fernando… – Continue reading

PH eyes tax treaties with Asean peers

The Philippines is eyeing to seal tax treaties with all nine other Asean member-states, according to the Bureau of Internal Revenue (BIR). The country already has effective double taxation agreements (DTAs) with Indonesia, Malaysia, Singapore, Thailand and Vietnam, BIR Assistant Commissioner Marissa O. Cabreros noted in a presentation at last… – Continue reading

UAE’s tax regime: The need of the hour

Creating of a Federal Tax Authority is the logical next step in seeing it through Within the span of month the UAE took two bold steps with the aim to develop a proper legislative and legal structure for the post-oil period. The first was to launch the Bankruptcy Law and… – Continue reading

India-Japan amended tax treaty comes into force

The amended bilateral tax treaty between India and Japan, which provides for strengthened exchange of information to help reduce tax evasion, has come into force from October 29. The agreement to amend the 27-year old Double Taxation Avoidance Agreement (DTAA) was signed when Japanese Prime Minister Shinzo Abe visited India… – Continue reading

OECD Reviewing U.S. Handling of Double-Tax Cases

The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading

McDonald’s UK pays £123m in royalties to Luxembourg

The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading

India-Korea DTAA notified, capital gains to be taxed at source

India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading

With 42% increase in trade, India-NZ agree to amend Double Taxation Agreement

India and New Zealand also vowed to press for successful negotiations of the Regional Comprehensive Economic Partnership (RCEP). India and New Zealand decided to amend the bilateral tax treaty and expressed commitment to work towards a comprehensive free trade agreement with a view to boost economic ties on Wednesday. The… – Continue reading

Armenia eliminates double taxation of property and income with Serbia and Slovakia

The Armenian Parliament has ratified today two agreements to avoid double taxation and prevent tax evasion with respect to taxes on property and income with Serbia and Slovakia. According to Deputy Minister of Finance Armen Hayrapetyan, the document on the mutual avoidance of double taxation on property and income with… – Continue reading

Hong Kong to commence automatic exchange of financial account information in tax matters with Japan and UK in 2018

Hong Kong has signed agreements with Japan and the United Kingdom with a view to commencing automatic exchange of financial account information in tax matters (AEOI) with these two tax jurisdictions in 2018, a Government spokesman said today (October 26). In September 2014, Hong Kong indicated its support for the… – Continue reading

Pakistan to seek offshore companies information from nine tax havens

Pakistan’s authorities are making efforts to seek information about tax details of 270 offshore companies from nine known tax havens around the globe where 444 individuals have invested billions of dollars, and, finally, their names appeared through PanamaLeaks, The News has learnt. The cases of 444 individuals involving nine jurisdictions… – Continue reading

Pakistan signs PTA with Mauritius

Governments of Pakistan and Mauritius on Friday signed a number of trade deals which included the Preferential Trade Agreement (PTA) – an agreement on avoidance of double taxation – which have a great potential for enhancing their bilateral trade. These agreements were signed during discussions held at the Mauritius Board… – Continue reading

OECD sets timeline for country profiles for cross-border tax disputes

The OECD has set the minimum standards it requires from countries submitting Mutual Agreement Procedure (MAP) profiles, with only 41 countries currently having a completed profile, which will be used as a tool for resolving cross-border tax disputes The MAP falls under Action 14 on the Base Erosion and Profit… – Continue reading

Japan, Austria Agree MAP Arbitration

The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading

Chinese dual tax burden relieved

An extensive tax treaty that would shield Chinese businesses operating in the Kingdom from double taxation, and vice versa, has been drafted and is expected to be approved imminently, according to a senior Cambodian tax official. Experts said yesterday the double taxation agreement (DTA) would create a clear legal framework… – Continue reading

China Issues More Rigorous Advance Pricing Agreement Rules

China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading

Turkmenistan ratifies deal with Germany to avoid double taxation

Turkmenistan in a bid to expand its bilateral ties with Germany in the trade sphere ratified an agreement on the avoidance of double taxation with respect to income and property taxes, the Turkmen government reported. The document signed with Germany was approved at the regular meeting of Parliament this week…. – Continue reading

Iran, Luxemburg agree on mutual investment, double taxation avoidance

The decision was made during a meeting between Iranian Finance and Economic Affairs Minister Ali Tayyenbia and the visiting Luxembourg Economy Minister Etienne Schneider in Tehran on Monday, IRNA reported. As reported, the Luxembourger minister also visited Central Bank of Iran Governor Valiollah Seif on Tuesday. Expressing satisfaction over the… – Continue reading

Gov’t, Chile agree deal to end ‘double taxation’

Argentina and Chile yesterday announced the implementation of a long-awaited agreement to eliminate double taxation for residents of both countries in order to encourage investment and prevent tax evasion. Chile’s Foreign Minister Heraldo Muñoz, Public Works Minister Alberto Undurraga, and Finance Minister Rodrigo Valdés met with Argentina’s Finance Minister Alfonso… – Continue reading

Ukraine and Luxembourg sign a Protocol modifying their double tax treaty

On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading

IRS, Mexico Reach Tax Deal For Contract Manufacturers

U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading

Georgia-Kyrgyzstan sign agreement on double taxation

Georgia and Kyrgyzstan are increasing economic cooperation by signing an agreement on avoidance of double taxation. The deal was signed today in Georgia’s capital Tbilisi and will prevent people or businesses working between the two countries from evading income and capital taxes. Double taxation is the levying of tax by… – Continue reading

BHP Billiton has evaded taxes for more than a decade, says Wayne Swan

Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading

Saudi joins talks on VAT, selective tax in GCC states

The Saudi Council of Ministers has authorized minister of finance or his deputy to discuss two draft uniform agreements on value added tax (VAT) and selective tax for Gulf Cooperation Council (GCC) states. The agreements shall be discussed within the framework of the GCC financial and economic committee, and sign… – Continue reading

Singapore wants to delay revision of tax treaty with India

Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into… – Continue reading

Taxation on corporate debt rules out for consultation

Revised rules affecting the way corporate debt and derivative contracts are taxed have now been drafted and are out for a brief consultation, in a bid to avoid double taxation and curb potential abuse HMRC has issued draft legislation for consultation following amendments to the Change of Accounting Practice Regulations… – Continue reading

Heat on tax evaders could be endgame for black money

Chances of tax evaders coming under the scanner is rising due to the implementation of the GST, greater use of technology and exchange of information between countries New Delhi: The noose is tightening around tax evaders. Be it the implementation of the goods and services tax (GST) or the greater… – Continue reading

US, Argentina Negotiating Comprehensive Double Tax Pact

During his remarks at a September 26 meeting with Argentine Finance Minister Alfonso Prat-Gay in Buenos Aires, US Treasury Secretary Jack Lew disclosed that the two countries are to negotiate a comprehensive double taxation agreement, to include provisions for the exchange of tax information. “To accelerate the process of sharing… – Continue reading

European Parliament Begins Panama Papers Probe Despite Tax Haven Splits

Members of the European Parliament, September 27, have begun their investigation into the Panama Papers scandal, which exposed the sheer extent of rich people and companies using offshore tax havens to reduce their tax liabilities in EU member states. However, the latest probe comes on the back of another investigation… – Continue reading

CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION

CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION As Prime Minister Justin Trudeau joined other world leaders in addressing the United Nations General Assembly, behind the glare of the camera lights, Foreign Affairs Minister Stéphane Dion met with Israel’s Finance Minster Moshe Kahlon on the sidelines to sign an agreement to… – Continue reading

Zimbabwe scraps double taxation with China to boost cooperation

The Zimbabwean government enacted a law last week to remove double taxation for individuals and firms doing business between Zimbabwe and China to boost economic cooperation between the two nations. Under the Statutory Instrument, investors in any of the two states would only be taxed in their country of operation… – Continue reading

Base erosion and profit shifting protocol: Small firms may get relief

The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading

Democrats Introduce Corporate Tax Transparency Bill in Congress

House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading

Wales to switch to Land Transaction Tax

Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading

Mauritius seeks India’s help, post tax treaty revision

Mauritius, the island nation that accounts for the second-largest FDI, has sought a line of credit and more investments from India as it gets ready for implementation of the revised tax treaty from April 2017. Mauritian Minister of Finance and Economic Development Pravind Kumar Jugnauth yesterday met Finance Minister Arun Jaitley… – Continue reading

Apple May Face Double Tax on Profits If France Adds to Tab

Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading

Cabinet approves formation of Goods and Services Tax Council, which will set the tax rate

The council will be chaired by Finance Minister Arun Jaitley and will make all the major decisions on the implementation of the new regime. The Union Cabinet on Monday notified and approved the formation of the Goods and Services Tax Council, the body that will oversee various issues regarding the… – Continue reading

India, Mauritius to discuss revival of FTA, two-way investments today

Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way… – Continue reading

MSAR signs tax agreement with Ireland

The Special Administrative Region yesterday signed a Tax Information Exchange Agreement (TIEA) with Ireland, according to an announcement by the Financial Services Bureau. The agreement was inked by the Secretary for Economy and Finance, Lionel Leong Vai Tac and Ireland’s Ambassador to China, Paul Kavanagh. According to the Secretary, the… – Continue reading

Tax evasion challenge Pakistan, Switzerland moving towards greater cooperation

Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double… – Continue reading

EU countries eye potential share of Apple windfall

Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading

Foreign portfolio investors approach government to iron out Singapore Treaty, GAAR issues

MUMBAI: Foreign portfolio investors (FPIs) are lobbying the government to resolve problems related to the India-Singapore tax treaty and general anti-avoidance rules (GAAR), worried about their investment in equities. FPIs fear after April 1, 2017, when both the renegotiated India-Singapore treaty and GAAR come into force, they will face challenges…. – Continue reading