I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading
I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading
The latest changes to VAT and profit tax legislation, implications of recent measures taken to fight fiscal evasion, changes to international tax reporting rules and the need to improve holding legislation were some of the topics discussed by participants in BR’s 14th Tax & Law conference which took place in… – Continue reading
Saudi Arabia is interested in increasing the trade turnover with Azerbaijan, Minister of Commerce and Industry of Saudi Arabia Tawfiq bin Fawzan Al Rabiah said at the Azerbaijani-Saudi Arabian business forum in Baku May 15. “Although Azerbaijan and Saudi Arabia signed the intergovernmental agreements on elimination of double taxation and… – Continue reading
The OECD plans to have international agreement on new tax rules developed as part of its project to tackle aggressive tax avoidance by multinationals through the Base Erosion and Profiting Shifting (BEPS) project by the next G20 summit in November, with implementation completed before 2020 ‘at the latest’ Pascal Saint-Amans,… – Continue reading
HE Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received HE Philip Parham, UK ambassador to the UAE at the Ministry of Finance (MoF) premises in Abu Dhabi. The two parties discussed the bilateral economic relations between the countries and the latest development regarding the rounds of negotiations… – Continue reading
Russia is set to enact an amnesty on offshore assets next month, but disagreement and lack of clarity over the terms of the pardon threaten not only to render the measure impotent, but undermine the government’s very drive to lure overseas money back home. The capital amnesty, part of a… – Continue reading
President Truong Tan Sang arrived at Heydar Aliyev international airport in Baku on May 13 afternoon for a three-day official visit to Azerbaijan. The President was welcomed at the airport by Azerbaijani Deputy Prime Minister Eyyubov Yaqub, Deputy Minister of Foreign Affairs Khalaf Aly Oglu Khalafov, Azerbaijani Ambassador to Vietnam… – Continue reading
Technology companies need to stop “extremely aggressive” tax planning, the man charged with reforming global tax rules has told the BBC. He says these “push the boundaries of what is legal”. Pascal Saint-Amans, who runs the OECD’s Centre for Tax Policy, said that new standards would require companies to pay… – Continue reading
The worldwide transfer pricing landscape is in a state of flux and the need for sound and reliable dispute resolution mechanisms has never been more important for multinational enterprises. In particular, where aggressive tax administrations such as India are concerned, double taxation is a key concern for businesses. Mutual agreement… – Continue reading
A Protocol amending the Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between South Africa and Cyprus was signed on the 1st of April 2015. According to the Protocol, Article 10 (“Dividends”) of the Double Tax Treaty… – Continue reading
Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading
There’s more trouble for Indians holding undeclared assets overseas as the black money bill passed by the Lok Sabha on Monday will disallow foreign tax credits, cutting off another loophole, reports the Economic Times. Holders of such assets that are not declared within the stipulated period will be denied credits… – Continue reading
Ireland and Pakistan signed a new Income Tax Treaty on 16 April 2015. Once in force and effective, the new Treaty will replace the existing on of 1973. The new treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect… – Continue reading
NEW DELHI: The Special Investigation Team on black money informed the Supreme Court on Tuesday that 339 accounts in HSBC bank held by Indians had a net amount of Rs 6,400 crore on which the income tax department has raised a demand of Rs 4,520 crore. “Amount of Rs 237… – Continue reading
Ireland and Zambia signed a new Income and Capital Tax Treaty on 31 March 2015. Once in force and effective, the new Treaty will replace the existing one of 1971. The new Treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will… – Continue reading
Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading
Georgia is stepping up cooperation in taxation, customs affairs and a number of other avenues with Cyprus, Liechtenstein and Iceland. Finance Ministers of Cyprus, Liechtenstein and Iceland signed a cooperation agreement with Georgia on avoidance of double taxation, prevention of evasion of income and capital taxes in Tbilisi today. Georgia’s… – Continue reading
The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading
The Ministry of Finance (MoF) recently organised a consultative meeting at its premises in Abu Dhabi; which was attended by key UAE foreign investment partners at a federal and local level. The meeting covered future plans to grow the UAE’s network of double taxation avoidance as well as protection and… – Continue reading
I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading
New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading
On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
Introduction The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) decided in mid-March 2015 that Switzerland should enter Phase 2 of the Peer Review. This decision represents a clear statement by the OECD that Switzerland’s legal and regulatory framework for information exchange complies with internationally… – Continue reading
The Income Tax Treaty between Guernsey and Monaco entered into force on 9 May 2015 and its provisions will take effect from 1 January 2016. The Treaty was signed on 7 April 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0%. Interest: 0%. Royalties: 0%.
The government should stop looking for more borrowed money and take immediate steps for resource mobilisation to overcome fiscal deficit Taxation is a lot like sheep shearing. As long as you shear a sheep, it will continue to produce a new crop of wool but you can skin the animal… – Continue reading
THE THAWING OF RELATIONS between the United States (US) and Cuba will open up the opportunity for Barbados to “serve as an intermediary for investment into Cuba”. But two prominent American lawyers, including one who advises Government, have warned that the “on paper” advantage Barbados has under its double taxation… – Continue reading
The Income and Capital Tax Treaty between Ireland and Thailand entered into force on 11 March 2015 and will enter into effect on 1 January 2016. The Treaty was signed on 4 November 2013. In accordance with the treaty, the following withholding taxes will apply: Dividends: 10%. Interest: • 0%… – Continue reading
Majlis Al-Shura held a regular session today under the chairmanship of vice speaker of the council Dr. Mohammed bin Amin Jafri. The council approved a draft agreement between the Government of the Kingdom and the Government of the Kyrgyz Republic on avoidance of double taxation and prevention of tax evasion… – Continue reading
The Government and the IRD are moving to crack-down on the big banks, overseas customers, and other offshore-owned entities that are not believed to be paying their fair whack of New Zealand tax. The IRD’s produced a 46 page issues paper making suggestions for new rules that would tighten up… – Continue reading
Minister of Revenue, Todd McClay today welcomed the release of an officials’ issues paper that seeks feedback on suggestions for helping to ensure that non-resident investors pay an appropriate amount of tax. The focus of the issues paper is the current non-resident withholding tax rules on interest earned in New… – Continue reading
The Italian Supreme Court (Corte di Cassazione) has decided that the Italian tax authorities may use details of foreign bank accounts in their tax compliance efforts, even if the data therein was obtained illegally. In a move that is thought likely to push more Italians with undeclared assets abroad towards… – Continue reading
The government has approved the report and application to the Diet a Tax Information Exchange Agreement (TIEA) and an additional protocol, as it was from the government building on Thursday. The agreement was signed in Rome on 26 February 2015. VADUZ. The TIEA is based on the applicable international standards… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to help Hong Kong capitalize on the increasing number of Chinese enterprises looking to invest and expand overseas. Introducing the report, “Chinese Enterprises ‘Going Global’: Opportunities and Hong Kong’s Policy Responses,”… – Continue reading
Exchange Traded Funds (ETFs) have gained huge popularity in recent times with Irish investors; however, there has been much complexity and uncertainty in relation to their tax treatment. The concept of an ETF is not specifically provided for in Irish tax legislation. It depends on the legal form and characteristics… – Continue reading
Arun Jaitley said that the governments of Switzerland, the UK and Spain have not provided details of any black money accounts, reports the Financial Express. The governments of Switzerland, the United Kingdom and Spain have not provided details of any black money accounts, Finance Minister Arun Jaitley said today. “No… – Continue reading
The United Arab Emirates and Romania signed a new Income Tax Treaty on 5 May 2015. Once the new treaty enters into force and becomes effective, it will replace the existing one of 1993. Further details will be reported once the new treaty text becomes available.
All the world’s major banks have connections between each other and work together in a secret network to help people evade taxes, whistleblower and former HSBC IT engineer Hervé Falciani said yesterday, warning that illegal offshore transactions can’t be carried out through one single bank but only with the help… – Continue reading
NEW DELHI: Ahead of Prime Minister Narendra Modi’s visit to South Korea this month, the Cabinet today approved revising the double tax avoidance pact with Seoul to provide tax stability and facilitate flow of investment and technology between the countries. The Cabinet headed by the Prime Minister gave its approval… – Continue reading
UK funds invested in India could face demands for tax from which they thought they were exempt. Minimum alternate tax (MAT), a tax on the book profit of a company, has been in existence in India in its current form since 2001 and is levied at 18.5 per cent. Because… – Continue reading
The Central Board of Direct Taxes [CBDT] on 26th March 2015 issued a Circular no. 4/2015 wherein they have clarified that while interpreting the provisions of Section 9(1)(i) of the Income Tax Act, 1961 [herein after referred to as ‘Act’] read with Explanation 5 inserted to the said section by… – Continue reading
The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading
In what may come as a relief to foreign portfolio investors (FPIs), the Bombay High Court has issued a stay on the tax department’s order seeking minimum alternate tax (MAT) from Aberdeen Global Emerging Markets. In what may come as a relief to foreign portfolio investors (FPIs), the Bombay High… – Continue reading
As discussed in our previous legal update The Tax Man Cometh: Not Only Long Awaited “Safe Harbor”, Notice No.7 is set to present a different income tax regime for non-tax resident enterprises (“Non-TRE”). In addition to the long awaited “Safe Harbor”, it is worth-noting that Notice No.7 has introduced new… – Continue reading
Dubai – The Ministry of Finance (MoF) recently signed a MoU with Ras Al Khaimah Investment Authority (RAKIA). This MoUhas been signed to ensure the implementation of international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD) regulations and… – Continue reading
It’s a race against time for governments of the worlds’ largest economies seeking a coordinated plan to make it more difficult for multinational corporations to shield profits overseas. Some countries are preparing to act on their own. International finance leaders from advanced- and developing- economies are set to gather Wednesday… – Continue reading
Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading
Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading
Part Seven in our series comparing ASEAN business costs with China Singapore is the de facto financial and services hub for ASEAN, and as a city state with such a remit it is more pertinent to compare the dynamics of Singapore with Hong Kong rather than China as a whole…. – Continue reading
