Category: Tax treaties

Finance Ministry gives up on tax row

Mumbai: The equity markets snapped their five-day losing streak following a late hour surge in buying of blue-chip stocks on reports that the minimum alternate tax (MAT) would not be levied on overseas investors coming through those jurisdictions with which India has a double taxation avoidance agreement (DTAA). After trading… – Continue reading

Relief for FIIs, India allays fears on tax claims topping US$6.4 bn

The government on Wednesday assured over 1,000 foreign institutional investors (FIIs) across the United States, Hong Kong and Singapore they can avail of treaty benefits to ward off tax demands on capital gains booked over the years till March 31, reports the Financial Express. The development is significant given the… – Continue reading

Jersey: Funds Quarterly Legal And Regulatory Update – 1 January 2015 To 31 March 2015

FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading

Budget 2015: striking a balance in an election year

Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading

Bitcoin is now VAT-Exempt in Spain

Bitcoin transactions are exempt from value-added-tax (VAT) in Spain, says Spanish tax lawyer Alejandro Gómez, The General Directorate of Taxes, a subsidiary of the Spanish taxing authorities, made the statement in a response to a request from Gómez. According to Gómez, the consultation found that Bitcoin payments were a form… – Continue reading

Ireland: Private Client Tax Ireland

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading

India Unties $6.4 Billion Tax Knot That Rattled Investors

India said foreign portfolio investors can use tax treaties to reject demands on past capital gains, seeking to defuse a row that cast a cloud over the $48 billion poured into stocks and bonds from overseas. Foreign institutional investors domiciled in countries that have signed double taxation avoidance treaties with… – Continue reading

Malta: Business, Investments And Residency Opportunities!

TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading

S’pore, Mauritius FIIs still out of MAT net: Dinesh Kanabar

Dinesh Kanabar, CEO, Dhruva Advisors explains that there are three kinds of FIIs: protected by double taxation avoidance treaty, no treaty but physical presence in India, and no treaty and no presence in India. So far notices have been sent only to the second category of investors. Minimum alternate tax… – Continue reading

New Agreement between Bulgaria and Romania for the avoidance of double taxation will stimulate bilateral business relations

Sofia. The Bulgarian government approved a draft of a new agreement between Bulgaria and Romania for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income. The document will be signed in case of following ratification. That is what the government information service announced…. – Continue reading

Why Finance Minister Arun Jaitley is Pranab Mukherjee 2.0 for the markets

The Finance Minister has failed to assuage markets’ fears on the issue of retrospective tax Markets are getting jittery each time the finance minister or his ministry utters the T word. Finance Minister Arun Jaitley reminds the market of UPA’s finance minister Pranab Mukherjee, who introduced the now-dreaded retrospective tax…. – Continue reading

China beefs up tax services to spur investment in Belt and Road

BEIJING, April 20 (Xinhua) — China’s taxation authority unveiled ten measures on Monday to improve taxation services for investors to serve the Belt and Road Initiative. The measures will protect investors’ interests, promote development and achieve a win-win outcome, said the State Administration of Taxation (SAT). Tax guides will be… – Continue reading

The Cost of Business in Myanmar Compared With China

Myanmar remains an enigmatic country – one of the largest and most populated in Asia but also one of its poorest and least understood. It remains a country that has largely stood still for seventy years – hardly any infrastructure of note was developed in the country since the end… – Continue reading

Global Law Experts distinguishes GRP Rainer Lawyers and Tax Advisors as a leading law firm in the field of tax law

The internationally recognized handbook for legal experts Global Law Experts has distinguished GRP Rainer Lawyers and Tax Advisors as one of the leading law firms in the field of tax law. GRP Rainer Lawyers and Tax Advisors in Cologne, Berlin, Bonn, Düsseldorf, Frankfurt, Hamburg, Munich, Stuttgart and London has been… – Continue reading

OECD MAP Statistics Show Pressing Need for Mandatory Binding Arbitration

The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading

Taxpayer Advocate Recommends Merging FATCA and FBAR Reporting Rules

The National Taxpayer Advocate has recommended that the reporting rules under the Foreign Account Tax Compliance Act and for foreign bank account reports in effect be merged to simplify the duplicative disclosure requirements that make it difficult for American expatriates to have bank accounts in the foreign countries where they… – Continue reading

OECD plans for gathering data on ‘base erosion’ at a disappointingly early stage, expert says

International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

‘Constructive’ talks on US banks tax evasion row

Tensions between Swiss banks and the United States justice authorities should ease up in 2015, Finance Minister Eveline Widmer-Schlumpf has said on the sidelines of the joint International Monetary Fund and World Bank spring meetings in Washington. The minister said she had received positive signals that this year would bring… – Continue reading

First Germany, now UK objects to India ‘breach’ of secret bank data

The United Kingdom (UK) has followed Germany in lodging a formal protest with the Finance Ministry over the alleged breach of confidentiality of data and secret banking details received via diplomatic channels. While German authorities objected to the manner in which 18 names of Indian account holders in the LGT… – Continue reading

China helps Indonesia track $500 million of ill-gotten assets

Chinese authorities will cooperate with Indonesia to confiscate more than $500 million of ill-gotten assets illegally transferred to China by corrupt Indonesian banking officials. Under the Treaty on Mutual Legal Assistance in Criminal Matters between China and Indonesia that took effect in 2006, the Ministry of Justice will “give support… – Continue reading

Cyprus: Cyprus’s New Double Taxation Agreement With Bahrain

On 17 March 2015 Cyprus and Bahrain signed a new double taxation agreement. Like all of Cyprus’s recent DTAs it closely follows the 2010 OECD Model Tax Convention. Its main provisions are summarised below. Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these… – Continue reading

Dixcart Releases Guide On UK’s Diverted Profits Tax

Dixcart, an international business support services provider, has released a new guide on the UK’s Diverted Profits Tax, which was altered ahead of its introduction on April 1, 2015. The DPT is intended to counter aggressive tax avoidance by multinational companies. It is charged at a rate of 25 percent… – Continue reading

Tax Traps & Retirement Planning Opportunities for American Entrepreneurs Abroad

It has never been easier for Americans to start businesses while living outside the U.S. If you are an American entrepreneur operating abroad, however, be aware of U.S. tax reporting obligations on non-U.S. businesses operated by Americans and make sure you are leveraging the value of U.S qualified retirement accounts… – Continue reading

Australia must break the shackles of intellectual property in FTAs

Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading

Saudi tax deal heralds increased efforts to boost trade, investment

Portugal’s deputy prime minister, Paulo Portas, and Saudi Arabia’s minister of trade, Tawfiq bin Fawzan Al-Rabiah, recently signed an agreement abolishing double taxation between the two countries, as part of a continued broader effort by Portugal’s government to boost exports and investment. The document was signed after a meeting in… – Continue reading

Fijian Attorney-General Receives Sultanate OF Oman Ambassador to Fiji

The Attorney-General, Hon. Aiyaz Sayed-Khaiyum today received the new non-resident Ambassador of the Sultanate of Oman to Fiji, His Excellency Nazar Al-Said. In welcoming the Omani envoy to Fiji, Minister Sayed-Khaiyum said that the Fijian Government looked forward to developing its bilateral relations with Oman, particularly in the areas of… – Continue reading

Germany-France cross border real estate transactions may need to be restructured, say experts

Cross border transactions involving German entities investing in French real estate may need to be restructured as a result of proposed changes to the France/Germany double tax treaty, according to two experts. French tax expert Franck Lagorce and German tax expert Werner Geisselmeier, both of Pinsent Masons, the law firm… – Continue reading

Manufacturing Groups Call For Corporate Tax Overhaul

Ahead of this week’s income tax filing deadline, the National Association of Manufacturers and the Manufacturers Alliance for Productivity and Innovation Foundation said the U.S. should exempt its companies’ foreign earnings from corporate taxes. In contrast to current tax policy, the groups’ analysis argued that exempting those earnings would allow… – Continue reading

Your Taxes: OECD helping governments collect more taxes

Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading

South Korea-Turkmenistan Summit Leads to US$13 Billion Plant Project

The South Korean government is going to construct a natural gas plant in Turkmenistan, which has the world’s fourth largest natural gas reserves. The government is supporting a US$13 billion scale project in total, which includes natural gas-to-liquids (GTL) plant construction and the modernization of essential oil factories. South Korean… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading