Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading
Kolkata Bench of Tribunal in the case of Outotec GmbH v. DDIT : ITA No. 431 & 432 of 2014 & 283 of 2015 (Kol) dealt with the issue as to whether the sale of equipment, designs and drawings would be taxable under the provisions of the India-Germany DTAA and… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading
Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading
HONG KONG: Pakistan and Hong Kong SAR signed a landmark agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income on Friday, a statement said. The agreement once implemented by Pakistan and Hong Kong SAR would encourage investment and business between the… – Continue reading
A new Protocol to the income tax treaty between Indonesia and the Netherlands was signed 30 July 2015 and will be effective 31 days after formal approval and ratification by both governments. Among the measures contained in the Protocol are revisions to the withholding tax rates on dividend payments. The… – Continue reading
The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the… – Continue reading
South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading
Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading
Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading
A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
The United States has rejected India’s claim that schemes such as Atal Pension Yojana, Rashtriya Swasthya Bima Yojana, Employees Provident Fund Organization and others should be taken into account while determining the size of population covered under social security schemes. In recently resumed talks on Totalization Pact, the US said… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading
The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading
Bern, 14.10.2015 – Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Oman and submitted it to Parliament for approval. The agreement will promote bilateral economic relations and contains provisions on the exchange of information upon request in accordance with the OECD standard. Aside… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
The number of letter box companies in the Netherlands continues to grow, despite both mounting criticism and tougher rules aimed at combating tax evasion, the Volkskrant said on Tuesday. The number of letter box firms – so called because they only exist on paper – rose 17% to 14,425 over… – Continue reading
Information on Completing the Form 8802, Application for United States Residency Certification Many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. The IRS provides this residency certification on Form 6166, a letter of… – Continue reading
Staff Correspondent The National Board of Revenue on Monday started negotiations with Bhutan to sign an agreement on avoidance of double taxation and prevention of tax evasion and capital flight from the country. A five-member delegation led by NBR chairman Md Nojibur Rahman has been carrying out the first round… – Continue reading
Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
With the adoption of the BEPS package, OECD and G20 countries, as well as all developing countries that have participated in its development, will lay the foundations of a modern international tax framework under which profits are taxed where economic activity and value creation occurs. Focus will now shift to… – Continue reading
Muscat: Bilateral trade between Oman and Spain has risen by 62 per cent, the European country’s top diplomat in Oman has said. Speaking at an event to celebrate his country’s National Day, Jose Urtasun, Spain’s Ambassador to the Sultanate, said, “Spain receives the most hydrocarbon exports from Oman of any… – Continue reading
India and Israel will sign a double taxation avoidance pact and explore ways to ramp up engagement in diverse sectors during President Pranab Mukherjee’s three-day historic visit to the Jewish state, the first by an Indian Head of State, beginning tomorrow, reports NDTV. Ahead of his visit, Israel said the… – Continue reading
PwC welcomes this effort to update international tax system and boost transparency. The tax landscape has been transformed by the globalisation of business and the advent of the digital age. We believe the existing international tax rules need to be modernised to reflect how business is done today, and it… – Continue reading
What has happened? On 5 October 2015, the OECD issued its final report on BEPS Action 4 – Limiting Base Erosion Involving Interest Deductions and Other Financial Payments (Paper). In this Alert we consider the main issues, recommendations and options for taxation reform raised in the Paper and consider the… – Continue reading
Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits offshore, a sufficient presence ”on the ground” can pull sales income (and… – Continue reading
During Sushma Swaraj’s visit, the nations also sign pacts on avoidance of double taxation and tax information exchange New Delhi: India and the Maldives have drawn up a new blueprint for bilateral ties that included closer economic and defence cooperation, pointing to a thaw in the relations following the Maldives’… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
KUWAIT: The Cabinet has called on ministers and senior officials of state bodies to submit their financial disclosure reports to the Anti-Corruption Authority as soon as possible. The call was made by the Cabinet during its customary weekly meeting held at Bayan Palace yesterday under chairmanship of HH the Prime… – Continue reading
Both internal and external factors threaten politics, economics Hong Kong’s run of good luck is running out. One obvious sign is the increasing interference of Beijing in its domestic affairs, most recently using tame Chief Executive C.Y. Leung and a clique of yes-men to interfere in a senior academic appointment… – Continue reading
EBENE, Mauritius, Oct 12 (Reuters) – Mauritius plans to launch a trading platform to hedge African currencies against the U.S. dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to… – Continue reading
A blistering attack on major countries who brand offshore financial centres as tax havens has been launched by Bob Richards. The Minister of Finance warned that pressure on the offshore sector from abroad will continue into the foreseeable future. Mr Richards, speaking at the launch of a British Virgin Islands… – Continue reading
The Federal Board of Revenue (FBR) will grant income tax exemption on interest payment to ICBC bank of China regarding coal-fired energy projects, subject to agreement and signing of third protocol between Pakistan and China under avoidance of double taxation treaty. Sources told Business Recorder here on Friday that the… – Continue reading
NAIROBI: The Kenya Revenue Authority (KRA) deserves a special commendation for daring to aim high by targeting to raise Sh5.3 trillion in the next three years. The tax body aims to do this, not by raising taxes—as some would advise it to—but by bringing into the tax bracket 4.4 million… – Continue reading
Merely because exemption has been granted under the Indian Income Tax Act, foreign tax credit cannot be denied The Karnataka High Court, in the case of Wipro Ltd, apart from other substantial questions on law, has held that tax credit for the income tax paid in a foreign jurisdiction shall… – Continue reading
Firm wants the new demand included in ongoing talks between India and Finland to resolve Rs 2,000-cr tax dispute Income Tax Department has slapped fresh tax notice on Nokia India, tax authorities said today. The Finnish telecom firm, however, wants the fresh demand to be included in the ongoing negotiations… – Continue reading
BARBADOS continues to be plagued by unjustified attacks from powerful nations, Prime Minister Freundel said yesterday as he confirmed two countries had moved to take Barbados off their tax haven blacklist. The Prime Minister told a two-day conference at the Hilton Barbados Resort, which forms part of International Business Week… – Continue reading
The Swiss Government has tasked the Finance Ministry with responding to the OECD’s recommendations on base erosion and profit shifting. Welcoming the OECD’s proposals, the Council said: “In general, the project outcomes will allow for [the] better coordination of international tax law rules and make it possible to close the… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
