The Netherlands has completed its ratification procedures for the entry into force of a new income tax treaty between the Netherlands and Germany. Therefore, the treaty will be effective beginning 1 January 2016. The Netherlands-Germany income tax treaty was signed in April 2012. The ratification process in the Netherlands took… – Continue reading
When considering which foreign assets are reportable under FATCA, one of the most commonly misunderstood and overlooked is the contribution to foreign pensions. Whether you are a U.S. citizen who worked abroad or a foreign national resident in the U.S., you may very well have some type of foreign pension…. – Continue reading
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
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
Canadian snowbirds could be trading winter’s bite for a bite from the taxman starting this year. Memos show the Canada Revenue Agency and Employment and Social Development Canada plan to use a planned border exit-tracking system to avoid paying hundreds of millions of dollars in social benefits now going to… – Continue reading
On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading
Shaikh Mohammed and Gruevski attended the signing of a double tax avoidance agreement between the governments of the UAE and the Republic of Macedonia. His Highness Shaikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, received Nikola Gruevski, Prime Minister of Macedonia,… – Continue reading
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
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
The French Ministry of Finance has issued guidance on the procedure for taxpayers to follow to reclaim wrongly charged social security contributions. The guidance has been issued following a European Court of Justice ruling in February in Ministre de l’Économie et des Finances v. Gérard de Ruyter. The case concerned… – Continue reading
The South African Revenue Service (SARS) has issued a revised guide to inform foreigners working in South Africa and their employers about their income tax commitments. The guide points out that, under the South African income tax system, amounts received by or accrued to persons other than residents (non-residents or… – Continue reading
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
More than three quarters of UK companies feel their approach to tax planning conflicts with HMRC’s expectations, a new survey has found, as corporates struggle to strike a balance between the needs of investors and tax authorities Law firm Allen & Overy found that 78% UK corporates believe their approach… – Continue reading
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
• 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
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
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 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
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
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
Global fund distribution company, Satori Consultancy, has launched a Hong Kong registered offshore pension plan structured by Legacy Trust Company (LTC) as an occupational scheme. The International Pension Plan, which has five risk graded investment portfolios run by Marathon Capital & Apollo Multi Asset Management, is a Hong Kong-based exempt… – Continue reading
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
Introduction The Internal Revenue Service (IRS) recently replaced Revenue Procedure 2006-54 for requesting assistance under the mutual agreement procedure (MAP) article of US tax treaties, and Revenue Procedure 2006-9 for requesting advance pricing agreements (APAs). New Revenue Procedures 2015-40 and 2015-41 largely track draft procedures issued in 2013 (Notices 2013-78… – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
The entire multi-billion euro aircraft leasing industry here paid Irish corporation tax of only €23m last year, reports the Irish Independent. That is according to figures provided by the Minister for Finance, Michael Noonan, who confirmed that the €23m paid in corporation tax last year was down from the €29m… – Continue reading
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
The convention between Ukraine and Luxembourg will be signed shortly, Ukrainian President Petro Poroshenko said at a joint press conference with Prime Minister of Luxembourg Xavier Bettel, who is now on a working visit to Ukraine. “As for the bilateral relations, I would like to note the significant progress that… – Continue reading
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
Taipei, Oct. 22 (CNA) Taiwan and Japan have made progress on negotiating a double taxation avoidance agreement, and are expected to sign more bilateral economic and trade-related pacts in the next few months, a Taiwanese foreign affairs official said Thursday. “The two sides have continued to negotiate the agreement on… – Continue reading
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 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
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
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
The Government has moved to boost the Revenue’s powers to tackle tax evaders and it is closing off loopholes used by companies, landlords and individuals to reduce their tax payments. The new measures are included in the Finance Bill, published on Thursday morning, which gives legislative effect to Budget 2016…. – Continue reading
Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system. In line… – Continue reading
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
Following last week’s publication of the various OECD/G20 reports on the Base Erosion and Profit Shifting (“BEPS”) project, the Irish Budget delivered on 13 October 2015 contains the first Government initiative on implementing some of the recommendations. Key features are the introduction of the first of its kind knowledge development… – Continue reading
National Treasury has decided to scrap a recently introduced incentive to make South Africa’s service sector more competitive, despite an impassioned appeal from multinational companies not to do so. The special foreign tax credit for service fees has protected companies from double taxation where South Africa’s treaty partners levied withholding… – Continue reading
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
Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading
Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading
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
Baku, Fineko/abc.az. Milli Majlis has ratified today the most important international agreement in the tax area. On the last day of its work the parliamentarians of the fourth convocation approved the Agreement on Compliance & Improvement of Compliance with the Tax Requirements of the Foreign Account Tax Compliance Act (FATCA)… – Continue reading
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
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
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
When a multinational company makes a cross-border investment, the relevant tax treaty between the two countries will generally sort out which country gets to tax which part of the ensuing activity and income streams. (Read more about tax treaties here.) A key question is this: how do the ensuing taxing… – Continue reading
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
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
The Base Erosion and Profit Shifting (BEPS) project, a joint initiative between G20 countries and the OECD, works towards the development of a coherent global taxation system which addresses BEPS concerns. The main purpose of such initiative is to address the gaps in the current international tax rules relating to… – Continue reading
