Tehran, Sept 6, IRNA – Economy Minister Ali Tayyebnia and visiting Iraqi Finance Minister Hoshyar Zebari, in a meeting on Sunday, signed three strategic economic agreements. The three agreements were about customs cooperation, avoiding double taxation and encouraging joint investments. Tayyebnia said that Iran-Iraq trade, including other cooperation such as… – Continue reading
On 1 July 2015, the Supreme Court (in Anson v HMRC4) held that a taxpayer was entitled to treaty relief on his share of a Delaware LLC’s profits. This casts doubt on HMRC’s published position (though each case must be judged on its own facts). The taxpayer, a UK “non-domiciled”… – Continue reading
Committing to a step-up in investments in India, the UAE said it is keen to tap opportunities in smart cities and the infrastructure sector. NEW DELHI: Just a little over a fortnight since Narendra Modi became the first Indian PM to visit the UAE in 34 years, the two countries… – Continue reading
Lack of information about ‘opaque’ special purpose vehicles make it difficult to assess financial stability implications The legendary Warren Buffett once described some shadow banking activities as “financial weapons of mass destruction”. By that he meant they pose a huge threat to the global financial system, as these investment structures… – Continue reading
International pensions administrator STM Group is looking to offer QROPS tailored for UK expats in Australia after HMRC scrapped thousands of schemes from its approved list in July. During an interview with International Adviser, STM – which has trading offices in both Malta and Gibraltar – cited plans to expand… – Continue reading
Investors could be hit hard if they are taxed on the capital gains earned from the sale of holdings in FPIs Today, a stable, predictable tax and regulatory regime is a sine qua non for creating a conducive climate for foreign portfolio investors (FPI). Investors wishing to invest in India… – Continue reading
One of Ireland’s richest persons, John P. McManus, seeks $5.2 million from the U.S. government after it was wrongfully withheld from his $17.4 million gambling winnings to cover taxes. In a complaint filed Monday in the U.S. Court of Federal Claims, McManus accuses the withholding agent of erroneously withholding the… – Continue reading
On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces current guidance, which was last updated almost 10 years ago, in Rev. Proc. 2006-54. Revisions to the former… – Continue reading
For the past few years, Canadians have been taking advantage of our dollar being worth about the same as the U.S. dollar. From buying up real estate to cross-border shopping, being on par with the U.S. dollar has had its advantages. However, in the last few months, economic factors have… – Continue reading
In addition to its main function to eliminate double taxation, a tax treaty is also intended to promote foreign direct investment (FDI). Investors normally consider the treaty networks of a targeted investment country in deciding their investments. The more extensive the treaty networks, the more attractive for the investors. Extensive… – Continue reading
On 4 August 2015, the Senate Economics References Committee tabled its report, Digital currency – game changer or bit player making a number of recommendations including: digital currency transactions should be treated in the same manner as money for the purposes of the goods and services tax (GST) and recommends… – Continue reading
Ambassador Furio De Angelis, the UN Refugee Agency’s man in Ottawa, says the media attention on the refugee crisis hitting Europe from all directions is a good thing, and one he hopes will translate into “concrete action.” He said the situation is dramatic, but it’s also a reflection of his… – Continue reading
International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading
Shifting of income between parent and subsidiary companies for the purpose of avoiding taxation has been a consistent concern for state departments of revenue. States have enacted a variety of rules to ensure that the entities involved file and pay taxes accurately. In Spring Licensing Group, Inc. v. New Jersey… – Continue reading
A resolution was published in Panama’s official gazette in early August 2015 that provides rules concerning benefits under income tax treaties for the avoidance of double taxation. Specifically, under this new guidance, taxpayers can seek a ruling from the tax authorities as to whether treaty benefits will apply to a… – Continue reading
Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading
India and Germany have agreed to resume negotiations on partial revision of double taxation avoidance agreement (DTAA), the government said on Friday. The two countries have agreed to explore possibilities of enhancing tax related information while continuing to share information on the basis of existing agreements, the ministry of finance… – Continue reading
It’s a decision that could spell relief for many Mauritius based investors. This week the Punjab & Haryana High Court has re-iterated that a Mauritian tax residency certificate is sufficient to avail treaty benefits. Senior advocate Porus Kaka tells CNBC TV18’s Menaka Doshi that this re-iteration is important given the… – Continue reading
The Luxembourg tax authorities issued a circular providing guidance and rules for issuing certificates of tax residence and access to application of income tax treaty provisions for the avoidance of double taxation for Luxembourg “undertakings for collective investment” or UCIs. The circular sets forth guidance for SICAVs / SICAFs and… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Zambia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Kenya for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
The government expects the number of disclosures about unaccounted overseas wealth under the black money window to go up in the last few weeks of the compliance period, which ends on September 30. “We expect the number of applications under the (black money) compliance window to go up during the… – Continue reading
Pakistan has decided to revise obsolete convention of double taxation and provision of fiscal evasion convention with the United State of America (USA) aimed at bringing the treaty at par with neighbouring countries, well informed sources told Business Recorder. Pakistan and US signed a convention on the avoidance of double… – Continue reading
Taipei, Aug. 27 (CNA) Taiwan and Japan have nearly completed negotiations on a bilateral agreement to avoid double taxation, a Taiwanese official said Thursday. The date of its signing is still being discussed, the official said. The negotiations on the agreement have almost been concluded, Chou Shyue-yow (周學佑), deputy director-general… – Continue reading
Tax authority alerts police amid suspicion that foreign companies have defrauded its system over past three years Denmark’s tax authority said on Wednesday that it had alerted police after foreign companies appeared to have drained more than 800m euros from the system in what would be the country’s biggest tax… – Continue reading
A recent Central Board of Direct Taxes (‘CBDT’) press release of August 6, 2015 announced signing of 2 unilateral APAs, including one with a rollback provision, and this has raised hopes of many MNCs, that hope to witness expeditious and reasonable closures. n July 2012, with a view to providing… – Continue reading
New de-offshorization and capital amnesty laws could have widespread effects In an attempt to encourage “economic patriotism,” Russia recently adopted two new laws: (1) The De-Offshorization Law, which makes a number of major changes in the existing systems of corporate and personal taxation in Russia, particularly as they pertain to… – Continue reading
Sofia. Bulgarian Council of Ministers approved at its regular Wednesday sitting an agreement on exchange of information on tax matters signed between the governments of Bulgaria and Guernsey. The cabinet proposes the National Assembly ratifies the document, the press service of the Government announced. The agreement sets conditions for the… – Continue reading
PRESS RELEASE Three Memoranda of Understanding (MOU)/Agreements on bilateral cooperation between Mauritius and Ghana in various fields were exchanged yesterday at New Treasury Building, in Port Louis. The documents concluded pertain to the following: mutual visa exemption; standardisation and conformity assessment; and, tertiary education. The exchange of MOUs was held… – Continue reading
In the overview of tax treaties as published on the website of the Irish Revenue, the Irish Revenue has published a statement announcing that the Convention between the Government of Ireland and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… – Continue reading
The Maltese climate, culture, history and lifestyle make Malta an attractive place to live in. The fact that this is coupled with a beneficial tax system for people taking up residence in Malta makes Malta an even more desirable location. Introduction to Malta Situated in the middle of the Mediterranean… – Continue reading
CHINA: MANAGING IP TAX CHALLENGES IN BEPS ENVIRONMENTABU DHABI // The UAE Embassy in Nairobi has temporarily suspended its consular services, it was confirmed on Tuesday. An employee at the embassy said that Kenyans wishing to apply for a work visa or attestations for the UAE will not be able… – Continue reading
The Revenue Department may soon come out with a circular on providing relief to FIIs from the minimum alternate tax (MAT) with retrospective effect. “Government is likely to soon issue circular giving relief to FIIs on MAT prior to April 1,” a senior Finance Ministry official said. The government-appointed AP… – Continue reading
India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading
MINISTER OF INTERNATIONAL Business, Donville Inniss is optimistic that given Barbados’ and Italy’s continued efforts at strengthening bilateral relations, Barbados could soon be removed from Italy’s blacklist. He made this disclosure this morning during his brief remarks at the end of a signing of a Double Taxation Agreement (DTA) between… – Continue reading
As another corporate reporting season in Australia draws to a close, the broad trend has been moderately underwhelming earnings results, combined with a rise in the earnings repaid to shareholders in the form of a dividend. During this recent reporting period Australian firms returned, on average, 73% of their profits… – Continue reading
Fuzhou, China, Aug. 24 (CNA) Lin Join-sane (林中森), chairman of Taiwan’s semi-official Straits Exchange Foundation (SEF), arrived in the southeastern Chinese city of Fuzhou on Monday in preparation for the next round of high-level meetings with his Chinese counterpart. Lin and the SEF delegation were greeted by Chen Deming (陳德銘),… – Continue reading
India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – Continue reading
In a recent decision (CAA Versailles, July 8, 2015, n°13VE01079), the Versailles Administrative Court of Appeals (CAA) provided an interesting illustration of the operation of the specific anti-abuse provision (i.e., different from the general abuse of law theory) attached to the dividend withholding tax exemption provided, in accordance with the… – Continue reading
LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading
In what could turn out to be a major relief for foreign investors, an expert committee has recommended that there was no case for imposing the controversial minimum alternate tax (MAT) on foreign institutional investors (FIIs) with retrospective effect. The A.P. Shah Committee, appointed to examine the issue of levying… – Continue reading
Improvement of the e-management system for value added tax The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on 16 July 2015. The law in its main part came into… – Continue reading
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – Continue reading
A case is pending before an appellate court in South Korea that could allow refunds of certain amounts of tax withheld on payments distributed to Luxembourg SICAVs. If the appeals are ultimately decided in favor of the SICAVs, they could be entitled to a refund of the difference between the… – Continue reading
Management and procurement services not taxable as “fees for technical services” under the India-UK income tax treaty: India’s Authority for Advance Rulings concluded that services rendered by a group director to its group company in India were “managerial services” that, as rendered by the UK procurement team, did not make… – Continue reading
Banks overseas, spooked by India’s stringent new black money law, are asking tough questions of people and entities from the country looking to open accounts with them, reports the Economic Times. That’s because it’s not just those who possess unaccounted wealth who will get punished, those found guilty of helping… – Continue reading
Many have, mistakenly, confused the prime minister (PM)’s recent remark that Rs 6,500 crore had been disclosed by holders of hitherto unaccounted money with disclosures under the compliance window in the recent law on the subject. However, this money has nothing to do with the latter’s three-month window. These came… – Continue reading
At first glance the OECD’s Base Erosion and Profit Shifting (BEPS) project is difficult to understand. There has been no decline in corporate tax revenues in recent years, and nations already possess a variety of tools to respond to erosion when needed. BEPS is thus drawing an inordinate amount of… – Continue reading
The IRS on 12 August 2015 released a revenue procedure—Rev. Proc. 2015-41—providing guidance and updated procedures regarding advance pricing agreements (APAs). Rev. Proc. 2015-41 addresses the process of how to request and obtain an APA from the IRS’s Advance Pricing and Mutual Agreement (APMA) program and with respect to the… – Continue reading
