Category: Tax treaties

Tax reforms will improve UAE’s investment status

Once the UAE fully implements the BEPS minimum standard, it will become a very good location, say tax experts The UAE’s position as an attractive destination for foreign investment will substantially improve once it fully implements minimum standards for base erosion and profit shifting (BEPS), tax analysts said on Saturday…. – Continue reading

Tax transparency watchdog urges Israel to step up moves against money laundering

After global index puts Israel in top third of most financially secretive countries, NGO calls for more public scrutiny and regulations to stop rich from hiding their assets Israel must immediately move to pass regulations against tax evasion and money laundering if it is to protect its credit rating and… – Continue reading

Avoidance of double taxation treaty between India, HKSAR comes into effect

A double taxation avoidance agreement between India and Hong Kong has come into effect from Friday, which officials say would stimulate more the two-way flow of investments and help curb fiscal evasion with respect to taxes on income. The agreement between India and the Hong Kong Special Administrative Region (HKSAR)… – Continue reading

Worldwide: UK Tax Round Up – November 2018

General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill… – Continue reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – Continue reading

FBR urged to clarify taxability of foreign rental income

There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for… – Continue reading

NRIs don’t need to reveal details of foreign bank accounts, assets to Indian tax dept: I-T Tribunal

The Income-Tax Appellate Tribunal (ITAT) has said NRIs do not need to reveal details of their foreign bank accounts and assets to Indian authorities. The tribunal has also ruled that the onus is on the I-T Department to prove an assessee has parked undeclared income arising from India in foreign… – Continue reading

India-China amends double taxation avoidance treaty

New Delhi, Nov 26 India and China have amended the bilateral tax treaty which will help prevent tax evasion by allowing exchange of information, the Finance Ministry said Monday. The Government of India and the People’s Republic of China have signed a protocol on November 26, 2018, to amend the… – Continue reading

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading

Cyprus: Entry Into Force Of The Protocol Amending The Convention On The Avoidance Of Double Taxation Between Cyprus And Mauritius

The Cyprus Tax Department has announced that the procedures for ratification of the protocol dated 23 October 2017 amending the Convention on the Avoidance of Double Taxation between Cyprus and Mauritius have been completed, and the protocol entered into force on 2 May 2018. The protocol replaces text of article… – Continue reading

Kenya and Mozambique move to remove double taxation, ease Visa rules

Foreign Affairs Cabinet Secretary Monica Juma says the move is aimed at eliminating double taxation. Juma and her Mozambique counterpart Jose Antonio Pachecho have constituted a Joint Commission of Cooperation tasked with this mandate ahead of the State Visit by Mozambique President Filipe Nyusi who will be hosted by President… – Continue reading

Angolan president seeking increased cooperation with Portugal

Luanda, ANGOLA, November 18 – Angolan head of state Joao Lourenco has pledged to raise bilateral cooperation with Portugal during his visit to European country scheduled for 22- 24 November this year. Joao Lourenco made the pledge during an interview with the Portuguese newspaper “Expresso”, on the eve of his… – Continue reading

Corporate America flees zero-tax Caribbean havens after crackdown

Many U.S. multinational corporations have packed up or are choosing to open subsidiaries in low-tax, rather than no-tax, countries that are seen as more legitimate than the formerly popular island destinations of the Cayman Islands and the Bahamas. They’re fleeing in response to regulations from the European Union that require… – Continue reading

Brazil and United Arab Emirates sign agreement to eliminate double taxation

Convention signed on Monday will facilitate investments, can reduce tax evasion Brazil and the United Arab Emirates signed an agreement to eliminate double taxation on income and prevent tax evasion and tax avoidance. The document was signed on Monday (12 November) by Brazilian Foreign Minister Aloysio Nunes Ferreira and UAE… – Continue reading

Tax Planning for NRIs Returning to India

In general, investment and tax provisions relating to non-resident Indians (NRIs) returning to live in India are fairly generous. However, NRIs must carefully plan their return to India to ensure there are no surprises with respect to managing their overseas income and investments. In this article, we examine some of… – Continue reading

European Union digital tax levy could be delayed until 2020

Arriving at the meeting Tuesday in Brussels, the Danish minister of Finance, Kristian Jensen, said of his side: “Everything is possible in politics but I think that it is very hard to reach an agreement on the taxation of the digital economy”. Under the proposal, a 3pc levy would be… – Continue reading

Applying for China’s DTA Benefits in Profit Repatriation

China’s double tax avoidance agreements (DTAs) can be used to avail lower tax rates while making outbound payments. However, DTA benefits are not automatically applicable to everyone. Foreign invested enterprises and their overseas headquarters must satisfy certain qualifications and go through relevant procedures to obtain the benefits. Beneficial owner assessment… – Continue reading

BIR may defer notice of foreign tax probe

THE BUREAU of Internal Revenue (BIR) may now notify taxpayers that their information was sent to a requesting foreign tax authority as investigation reaches the final stages. Revenue Regulation No. 22-2018 states that the Commissioner of Internal Revenue can opt to notify the taxpayer in writing that a foreign tax… – Continue reading

Cyprus: Approach Of Greek Authorities In Determining A Valid Foreign Proof Of Tax Residence

In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading

UK and Cayman resume crime-fighting cooperation after row

The UK and the Cayman Islands have reached an agreement that will allow the continued cooperation in the fight against money laundering and other crime after complaints from London that information was not being shared. The minister of state for the Overseas Territories Tariq Ahmad and premier Alden McLaughlin released… – Continue reading

Defying US, India inks $5 bn deal with Russia

NEW DELHI: India and Russia are exploring the option of trading in their local currencies and looking at signing agreements on investment protection and avoidance of double taxation, Russia’s minister for economic development Maxim Oreshkin said on Friday. The commerce ministry is considering the feasibility of a renminbi-rupee trade with… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 1

1.Introduction Due to the influence of International Monetary Fund, the income tax law of Sri Lanka witnessed a near paradigm shift with the introduction of Inland Revenue Act No.24 of 2017 (new IRA) by repealing Inland Revenue Act No.10 of 2006 with effect from 1 April 2018. Unlike the Inland… – Continue reading

Tax Residency in China under New IIT Law: Impact on Foreigners

How tax residency in China gets determined is among key changes introduced in the recently passed individual income tax (IIT) law. The new law is set to reform IIT in the country, including the tax treatment of foreigners. Beginning January 1, 2019, an individual who resides in China for 183-days… – Continue reading

TAX MATTERS | THE TAXATION OF COMPANIES IN MACAU – WORLDWIDE OR TERRITORIAL BASIS? (CONT.)

Our previous article about the taxable basis for the taxation of companies in the Macau territory made reference to the fact that the courts in Macau, notably the Court of Second Instance (TSI) and the Tax Administration, do not seem to share the same view regarding income considered as the… – Continue reading

Govt to serve notices to 300 Pakistanis owning properties in UAE: sources

ISLAMABAD: The federal government has decided to issue notices to 300 Pakistani nationals who own properties in the United Arab Emirates, sources informed Geo News Saturday. The sources said that notices will be sent to individuals who own six or more properties in UAE. They will be inquired about their… – Continue reading

IN UKRAINE A NUMBER OF TAXES IS TOO HIGH – EXPERT

In Ukraine in some areas taxes are too high, and entrepreneurs simply can’t pay, so toughen system of tracking defaulters only after tax cuts. Comments about this correspondent of ГолосUA said political analyst Nikolai Spiridonov. “In Ukraine, a number of taxes too high. Businesses simply can’t pay. And is double… – Continue reading

Withholding Taxes – What, why, when?

The tax regime in Sri Lanka historically imposes WHT on both domestic as well as cross border payments. WHT on domestic payments eases revenue collection (e.g.: PAYE) while WHT on cross border payments are adopted by most countries to ensure that the fair share of tax is retained in the… – Continue reading

McDonald’s Luxembourg tax deal not illegal

BRUSSELS (Reuters) – McDonald’s tax deal with Luxembourg did not breach EU state aid rules, EU antitrust regulators ruled on Wednesday, saying the reason the US fast food chain did not pay some taxes was due to the mismatch between US and Luxembourg laws. The decision by the European Commission… – Continue reading

Kazakhstan ratifies protocol amending double taxation avoidance deal with Uzbekistan

President of Kazakhstan Nursultan Nazarbayev has signed the law on ratification of the protocol between Kazakhstan and Uzbekistan on avoidance of double taxation of incomes, the press service of the head of state reported Sept. 18. “The head of state has signed the law of the Republic of Kazakhstan “On… – Continue reading

Gibraltar enters Brexit negotiations

Spain’s Prime Minister Pedro Sánchez is scheduled to meet with the European Union’s chief negotiator Michel Barnier to push for an annex addressing smuggling in the British territory, as well as cross-border workers and tax evasion. Gibraltar is also on the agenda. As for Gibraltar, however, Spain will reportedly not… – Continue reading

Chasing tax evaders worldwide

Indonesia is set to join the global treaty on the Automatic Exchange of Information (AEOI) on tax matters this month, and will then have virtually all the “high-caliber weapons” it needs to hunt down tax evaders — not just within the country but anywhere in the world, including tax-haven countries…. – Continue reading

Panasonic to Move European Headquarters Out of UK as Brexit Concerns Grow

Several multi-national corporations have moved their European headquarters outside of the UK ahead of Brexit, and many others are expected to follow suit, especially as the likelihood of a no-deal Brexit rises further. Japanese tech giant Panasonic will be transferring its European HQ away from London to Amsterdam in October… – Continue reading

Automatic exchange of tax evaders data from September 1: FBR

ISLAMABAD: The Federal Board of Revenue (FBR) on Monday informed the task force constituted by the Prime Minister to repatriate laundered ill-gotten funds that newly installed computer software would ensure the automatic exchange of information about tax evaders with the Organisation for Economic Cooperation and Development (OECD) from September. The… – Continue reading

Government approves double taxation avoidance pact with Macau

Hanoi (VNA) – The Government has approved an agreement between Vietnam and China’s Macau Special Administrative Region on the avoidance of double taxation and prevention of income tax evasion. The Government assigned the Ministry of Finance to chair and coordinate the two sides’ relevant agencies to implement the pact. The… – Continue reading

UK – GOVERNMENT PUBLISHES OFFICIAL GUIDANCE ON ENGAGING WITH UMBRELLA COMPANIES

The HMRC published an official guidance yesterday on engaging with umbrella companies in the UK. The guidance provides advice and spotlights umbrella companies that effectively operate tax avoidance schemes. “Most employment agencies and umbrella companies operate within the tax rules. However, some umbrella companies and agencies promote arrangements that claim… – Continue reading

Receipts from Web Hosting Services to Indian Entities can’t be treated as FTS under Indo-US Tax Treaty: ITAT [Read Order]

The Mumbai bench of the Income Tax Appellate Tribunal ( ITAT ) has held that the income earned from the web hosting services cannot be treated as fee within the meaning of Article 12 of the Double Taxation Avoidance Agreement (DTAA) between India and US. In the instant case, the… – Continue reading

Nigeria Concludes Double Tax Treaties With Ghana, Cameroon

The Federal Government of Nigeria (FGN) concluded the negotiation of Double Taxation Agreements (the DTAs) with the Republic of Ghana and the Republic of Cameroon on 26 July 2018 and 3 August 2018, respectively. While this is a welcomed development, it is expected that efforts will now be directed towards… – Continue reading

Uber withdraws lawsuit against HCMC tax man

Ride-hailing firm Uber has withdrawn its lawsuit over HCMC’s demand for $2.3 million in back taxes and fines. A tax department official said Friday that the HCMC People’s Court has suspended the case in which the Netherlands-based Uber B.V. had sued the department over its demand that the firm pays… – Continue reading

Sri Lanka And Oman Sign Agreement On Avoidance Of Double Taxation, Tax Evasion

An agreement on Avoidance of Double Taxation and Prevention of Fiscal Evasion between Sri Lanka and Oman was signed during the Second Meeting of the Sri Lanka-Oman Bilateral Consultations, held on August 15, 2018 in Colombo at senior officials’ level by the leaders of the respective delegations. The Sri Lankan… – Continue reading

Booksellers urge government to ‘act quickly’ on ‘Amazon tax’

News that the government may bring in an ‘Amazon tax’ to help “rebalance the playing field” between physical and online retailers has been welcomed by booksellers. After department store retailer House of Fraser became the latest high street chain to go into administration on Friday (10th August) Philip Hammond said… – Continue reading