NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading
In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the… – Continue reading
Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading
The National Assembly endorsed the double taxation avoidance agreement between Bhutan and Bangladesh yesterday. Signed during the visit of Bangladesh Prime Minister Sheikh Hasina to Bhutan in April 2017, the agreement plans to do away with double taxation of incomes between the two countries. In the presence of 38 MPs,… – Continue reading
NAIROBI, Nov. 16 (Xinhua) — The East African Community (EAC) member states are set to ratify the avoidance of double taxation treaty in order to boost regional integration, a Kenyan official said on Thursday. Barrack Ndegwa, Regional Integration Secretary in the Ministry of EAC, Labor and Social Protection, told Xinhua… – Continue reading
The Swiss Federal Council has adopted a dispatch on the implementation of a new double tax agreement (DTA) with Kosovo. The agreement was signed in May. A previous DTA was in force until 2011. The DTA caps the maximum withholding tax rate for dividends being taxed at source at 15… – Continue reading
Even Israelis residing overseas for three years are being required to pay tax in Israel on their income during that period. Quite a few Israelis who emigrated from Israel, lived abroad for certain periods, and did not report their income there, claiming that they are not residents of Israel, have… – Continue reading
The Ministry of Finance (Department of Revenue) vide notification S.O. 3512(E) dated November 2, 2017 sets out the Third Protocol to the Convention between the Government of the Republic of India and the Government of New Zealand for the avoidance of double taxation and the prevention of fiscal evasion with… – Continue reading
The Cabinet today gave its green light to an agreement between India and the Hong Kong Special Administrative Region (HKSAR) of China for avoiding double taxation and prevention of tax evasion. The Cabinet, chaired by Prime Minister Narendra Modi also approved the protocol amending the agreement between India and Kyrgyzstan… – Continue reading
The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The… – Continue reading
The EU Economic and Financial Affairs Council has adopted a Directive to create a new system to resolve double taxation disputes between EU Member States. This measure will afford taxpayers a transparent process with clear deadlines applicable to tax authorities involved to resolve cross-border double tax disputes within the EU…. – Continue reading
BRIDGETOWN, Barbados, Thursday November 2, 2017 – The Double Taxation Agreement (DTA) between the Government of Barbados and the Italian Republic has entered into force. The instruments of ratification for the Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion… – Continue reading
The Treasury says the Isle of Man has become one of the first countries to sign a new international treaty against tax avoidance. The Island joins Austria in agreeing to the OECD’s Multilateral Convention to Implement Tax Treasury Related Measures to Prevent Base Erosion and Profit Shifting. The agreement aims… – Continue reading
Summary: With effect from 1 January 2017, a number of amendments to Russian law have come into force which will affect aircraft leasing arrangements for lessors and financiers that have aircraft leased or financed with Russian operators. These amendments have started to affect negotiations and re-negotiations of leases with Russian… – Continue reading
BERN – The Swiss Federal Council has adopted a dispatch on the implementation of a new double taxation agreement (DTA) with Pakistan, according to the Tax News. The DTA was signed in March. According to the Swiss Federal Council, the agreement makes a number of improvements to the previous DTA,… – Continue reading
Peru takes one step further in the eradication of tax avoidance and evasion after signing the Convention on Mutual Administrative Assistance in Tax Matters with the Organisation for Economic Co-operation and Development (OECD). Deputy Director of the OECD‘s Centre for Tax Policy and Administration Grace Perez-Navarro affirmed these two crimes… – Continue reading
Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the… – Continue reading
The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which… – Continue reading
Oman has become the latest country to agree to implement the base erosion and profit shifting minimum standards by signing up to the BEPS Inclusive Framework. In implementing the minimum standards, countries agree to remove harmful tax provisions in their domestic tax regimes, amend their tax treaty rules to prevent… – Continue reading
MUMBAI, OCTOBER 25: Networking giant Google has said it will continue its fight in a six-year-old tax avoidance case after the Income Tax Appellate Tribunal asked the company to pay ₹1,457 crore in back taxes. “We comply with all tax laws in India and pay all applicable taxes. We will… – Continue reading
Bad news for the world’s favourite search engine. On Tuesday, the Indian tax office gained an upper hand in its six-year-long battle with Google India in a ruling that would set a precedence for some of the other multinational companies. The rift owes its origin to the arrangement and fund… – Continue reading
Heads of the Armenian and Iranian tax entities met for the first time in Yerevan on Monday and expressed their willingness for deepening cooperation. The two sides also discussed updating the 1998 double taxation treaty. “It is time to edit the current agreement in line with the latest developments in… – Continue reading
Paul Chan Mo-po says the city must protect against unforeseen market changes at a tax forum that also featured a warning about the city’s international tax compliance There are no plans to cut Hong Kong’s corporate taxes across the board because the government needs to reserve funds to protect the… – Continue reading
THE Bahamas yesterday upgraded its tax information exchange agreement with Finland to the automatic variety, as it bids to meet global standards by September 2018. K P Turnquest, deputy prime minister, signed the Protocol to Amend the Tax Information Exchange Agreement between the Bahamas and Finland, with the latter’s ambassador… – Continue reading
Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading
The Japanese and Danish governments announced on October 11 that they had signed a new agreement for the avoidance of double taxation in Tokyo. The Japanese Ministry of Finance said: “This Convention wholly amends the existing Convention, which entered into force in 1968, by revising the taxation on business profits,… – Continue reading
The Irish Government has published an updated version of its International Tax Strategy, which provides an overview of the steps taken to meet international standards and sets out the Government’s position on global reform efforts. In his foreword to the Tax Strategy paper, Finance Minister Paschal Donohoe said: “In Ireland… – Continue reading
European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding… – Continue reading
Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not… – Continue reading
Ireland is set to taste cold justice at the hands of the EU which has taken it to the European Court of Justice (ECJ) for failing to collect a year-old tax bill of a whopping 13 billion euros from American tech giant Apple. To be sure, the EU competition commission… – Continue reading
Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 5) Bill 2017 (Amendment Bill) was gazetted today (October 6). The Amendment Bill seeks to pave the way for Hong Kong’s participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and to align the Inland Revenue Ordinance (IRO)… – Continue reading
SAN JOSE- Manuel A. Gonzalez Sanz, Costa Rica‘s Minister of Foreign Affairs and Worship, has met with Mohammed Sharaf Al Hashemi, Assistant Minister of Foreign Affairs and International Cooperation for Economic and Commercial Affairs, at the ministry in capital San Jose. During the meeting, the UAE and Costa Rica signed… – Continue reading
The Russian President and the Japanese Prime Minister signed the Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (the “Convention”) on 7 September 2017. The Convention will replace the existing treaty signed in 1986 by the Soviet… – Continue reading
The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for… – Continue reading
MINSK, 26 September (BelTA) – Belarus and the UK have signed an intergovernmental convention on removing double taxation in respect to income and capital taxes and preventing tax evasion, BelTA informs. The signing ceremony took place at the Belarusian Ministry of Foreign Affairs. The document was inked by Belarus’ Taxes… – Continue reading
ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading
NAIROBI (Xinhua) — Kenya and China on Thursday signed an agreement on the avoidance of double taxation that aims to boost bilateral commercial ties, Kenyan officials said. Cabinet Secretary in the National Treasury Henry Rotich told a media briefing in Nairobi that the deal will create certainty to the tax… – Continue reading
YEREVAN, September 25. /ARKA/. Until 2022 Armenia will conclude agreements on the exclusion of double taxation with 8 more countries and will pursue an agreement also with the United States to abolish double taxation, Armenian finance minister Vardan Aramyan said at a press conference on Monday. So far Armenia has… – Continue reading
Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the… – Continue reading
On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading
In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading
Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading
Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading
The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading
PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading
Canada’s Revenue Minister has provided an update on the progress made by the Government in addressing tax evasion and aggressive tax avoidance. The update concerns the recommendations on tackling tax avoidance and evasion made by the House of Commons Standing Committee on Finance (FINA) in October 2016, and the actions… – Continue reading
Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a… – Continue reading
Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the… – Continue reading
Mauritius’s Ministry of Finance has denied that there are plans for a renegotiation of the jurisdiction’s double tax agreement with India in the near future. The Ministry stated: “Further to press articles alleging that Mauritius and India are to begin a fresh round of negotiations to amend the Double Taxation… – Continue reading
On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion (“Tax Treaty”) between Belgium and Mexico was published in Mexico’s Official Journal of the Federation (Belgium publication pending). The Tax Treaty became effective in Belgium on August… – Continue reading
