The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
Turkmen parliament ratified the country’s convention with South Korea on double taxation avoidance and prevention of fiscal evasion with respect to income taxes, the Turkmen government said August 19. Aside from that, according to the government message, the parliament ratified the country’s convention with Austria on avoidance of double taxation… – Continue reading
On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading
The Singapore Shipping Association (SSA) is pushing for the city-state to have more double taxation agreements. Speaking at a media briefing on Tuesday, Rene Pedersen, chairman of the SSA International Committee said, “Singapore today has some 65 double taxation agreements and that’s actually not a lot.” By comparison the UK… – Continue reading
A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading
In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading
Taipei, Aug. 18 (CNA) Taiwan and China will sign two agreements on taxation and aviation safety in their next high-level meeting to be held in Fuzhou, China later this month, a senior official of Taiwan’s Mainland Affairs Council (MAC) announced Tuesday. The meeting between the chiefs of Taiwan’s Straits Exchange… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
In short… The current balance of competences between the EU and the UK on tax is quite intricate, with a tension between member states’ desire to determine their own tax systems and the EU-led aim of a level playing field. The EU most obviously influences member states’ indirect taxation (particularly… – Continue reading
The tax regime for foreigners who render services in South Africa for a relatively short period of time is a key area which expatriates and their employers are grappling with. These individuals (also more commonly known as ‘short-term business travellers’) are generally physically present in SA for periods ranging from… – Continue reading
Simplification of tax administration has always been on the government’s agenda. E-filing is one major steps in that direction as it increases the tax base. E-filing is almost paperless, where taxpayers need not submit any supporting documents. E-filing is mandatory for those qualifying as resident and ordinary resident and having… – Continue reading
Gaborone — Botswana and Mauritius on Saturday August 15 signed a Double Taxation Avoidance Agreement, renewing a convention the two countries have had since 1995. Minister of Finance and Development Planning, Mr Kenneth Matambo represented Botswana while Mauritius’ Minister of Foreign Affairs, Regional Integration and International Trade, Mr Marie Joseph… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
Hong Kong (HKSAR) – The agreement between Hong Kong and Italy for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion has entered into force. The Secretary for Financial Services and the Treasury, Professor K C Chan, said today (August 14), “Hong… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
A new income tax treaty between the Bulgaria and the United Kingdom was signed in March 2015. The treaty, once it is ratified and enters into force, will replace the existing income tax treaty (1987). The new income tax treaty includes measures that differ from the provisions under the current… – Continue reading
The Swiss Federal Council has adopted a dispatch on the implementation of a tax information exchange protocol to its double tax agreement (DTA) with Italy. The protocol to the 1976 DTA was signed on February 23, 2015. It brings its information exchange provisions into line with the Organisation for Economic… – Continue reading
The Polish Ministry of Finance has published the text of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as concluded on July 13, 2015 between The Republic of Poland and the Federal Democratic Republic of Ethiopia (Hereafter: the… – Continue reading
The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading
The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading
The IRS today released two revenue procedures that that provide guidance regarding the advance pricing agreement (APA) program, and that offer guidance on the process for taxpayers to request and obtain the assistance of the U.S. Competent Authority under the U.S. network of income tax treaties. Rev. Proc. 2015-41 [PDF… – Continue reading
In doing business, companies will incur operating costs that vary according to the nature of the undertaking. For manufacturers, the key operating costs, apart from raw materials and overheads, might include such expenses as manufacturing know-how and technical assistance. For distributors, the key operating costs will normally include inventory, marketing… – Continue reading
QROPS specialists are offering free transfers to Gibraltar QROPS for August only for teachers who want to retire abroad and avoid all UK taxes and future UK taxes on their existing teacher’s pension scheme. This is the final chance for teachers living abroad to transfer their UK pensions outside the… – Continue reading
On August 10, 2015 the Dutch Government published the text of a Protocol amending the Agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on… – Continue reading
FOLLOWING A PROTEST from the Ministry of International Business, Spain has removed Barbados from its tax blacklist. This latest development comes after a recent decision was taken by members of the European Union to blacklist this country for being a non-cooperative tax jurisdiction. International Business Minister, Donville Inniss, praised the… – Continue reading
India follows common approach for implementation of FATCA and CRS New Delhi, Aug 8: The Finance Ministry has come up with the rules for information reporting under the Foreign Account Tax Compliance Act (FATCA), spelling out the timelines and the entities have to comply with the new requirements. The new… – Continue reading
The $100 billion is flowing across borders in search of takeovers and start-up ventures. Developing countries are losing around $100 billion a year in revenues because foreign investors are channelling profits through offshore zones to avoid tax, a study by U.N. think-tank UNCTAD said. “Tax avoidance practices therefore are responsible… – Continue reading
The Organisation for Economic Co-Operation and Development (OECD) is likely to recommend that restrictions on interest deductibility should mainly involve a cap calculated as a percentage of EBITDA, an expert has said.07 Aug 2015 Corporate tax Tax International tax Energy Infrastructure However Heather Self of Pinsent Masons, the law firm… – Continue reading
A FATCA issue that has recently bubbled up relates to the differing approach to FATCA compliance by the U.S. Treasury and the governments of some countries, notably, the United Kingdom and Canada, with respect to the self-certification requirements for new individual account openings under an Intergovernmental Agreement (IGA). Both sides… – Continue reading
SEOUL, Aug. 6 (Yonhap) — The top court ruled Thursday against an oil company of the United Arab Emirates, headed by a member of the Abu Dhabi royal family, saying that it must pay millions of dollars in stock trading tax to South Korea. IPIC International B.V. (IPIC), a state-run… – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
Muscat – H E Christian Winter, Switzerland’s Ambassador to Oman has said that the recently signed Double Taxation Agreement (DTA) between his country and the sultanate reflects the broader ties Switzerland seeks with GCC. “The conclusion of the agreement takes into account the growing economic and political importance of the… – Continue reading
One European country’s generous tax regime to entice wealthy expats is looking even more attractive thanks to pension freedom. Many dream of retirement in sunnier climes and with pension freedom the opportunity to take your savings and run is even more tempting. A reduced tax bill is even more enticing,… – Continue reading
The recommendations of Justice AP Shah-led three-member committee on minimum alternative tax (MAT) has come in for big relief to foreign investors. The 64-page report, exclusively accessed by dna, says a foreign investor is not liable to pay MAT prior to April 1, 2015. The report, however, is silent on… – Continue reading
Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading
Tax Commissioner Pierre Moscovici has said that European Commission law was not breached in the case of a French professional association taxing royalty payments earned by UK musicians in France. In a written question to the European Commission, Julie Girling, a UK Member of the European Parliament (MEP), alleged that… – Continue reading
Introduction Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
Currently, olim are exempt from Israeli tax on overseas income and gains for 10 years. Now that the Israeli election is long forgotten, government officials have circulated their decisions on what state budget proposals should be presented to the cabinet for approval and submission to the Knesset for enactment. Some… – Continue reading
Cyprus and the Islamic Republic of Iran signed a double taxation and a fiscal evasion treaty which aim at helping the two countries develop bilateral trade and economic links, the finance ministry said today. “Expansion and upgrading the network of double taxation agreements, is of high economic and political importance… – Continue reading
The Government of Jersey has signed a Double Tax Agreement (DTA) with the Republic of Seychelles. The agreement was signed in London on 28 July 2015. The deal is part of a programme by Jersey that aims to develop closer economic and taxation co-operation with other countries. The DTA is… – Continue reading
United Kingdom Budget The Chancellor of the Exchequer delivered his Summer Budget to the United Kingdom (UK) Parliament on 8 July 2015. A number of personal, corporate and indirect tax-related measures were announced in the Budget including a reduced corporate tax rate; introduction of a bank corporation tax surcharge; a… – Continue reading
Australian QROPShave been closed down and kicked off HMRCs ROPS list bar one the LG Super Australian Superannuation scheme which is the Aussie government scheme. QROPS Specialists are offering free QROPS transfers from any Aussie QROPS to a Malta QROPS. The transfer fee and set up fee will be waived…. – Continue reading
British expats in Cyprus could lose a host of privileges if Britain withdraws from the EU, a popular expat forum has warned. The website is urging them to register to vote in the UK’s in/out referendum, which could take place as early as the middle of next year. The vote’s… – Continue reading
MUMBAI: The Financial Services Commission (FSC) of Mauritius, which is the regulatory body for the Mauritian non-banking financial services sector, has introduced a new application form for obtaining a tax residency certificate (TRC). FSC verifies these applications and recommends issue of the Mauritius tax residency certificate by the Mauritius revenue… – Continue reading
The Barbados Revenue Authority (BRA) was subjected to rigorous assessments by the United States Internal Revenue Service (IRS) recently in a bid to verify the island’s readiness to enact the Foreign Account Tax Compliance Act (FATCA), reports Barbados Today. Anthony Gittens, the BRA’s manager of policy and planning, said as… – Continue reading
The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief Counsel issued an advice memorandum regarding the applicability of the tax returns and return information confidentiality… – Continue reading
NEW DELHI: Government today said the tax department will expeditiously process the cases where FIIs have claimed exemption from minimum alternate tax (MAT) as a benefit under the bilateral tax treaties. “The CBDT ( Central Board of Direct Taxes) has directed its officers to expeditiously process the cases where the… – Continue reading
While the traders have announced shutter down strike on August 01 (Saturday), the All Pakistan Business Forum (APBF) has endorsed their stance on 0.3% WHT on banking transaction, persuading the government to withdraw this tax to avoid any confrontation. President All Pakistan Business Forum Ibrahim Qureshi, said that the government,… – Continue reading
Three former chief executives of major listed companies have recently moved from Finland to Portugal. Matti Halmesmäki, a 62-year-old former chief executive at Kesko, Sakari Tamminen, a 61-year-old former chief executive at Rautaruukki, and Kim Gran, a 61-year-old former chief executive at Nokian Tyres, have all transferred their residence to… – Continue reading
