The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading
Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading
Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double… – Continue reading
Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading
A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading
Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection The long-awaited Comprehensive Double Taxation Agreement (CDTA) between Hong Kong and Russia entered into force on July 29, 2016. The agreement will take effect on April 1, 2017 in Hong Kong and January… – Continue reading
In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are… – Continue reading
The comprehensive double taxation agreement (CDTA) between Hong Kong and Russia, which was signed in January this year, entered into force on July 29, 2016, and will be in effect in Hong Kong for any year of assessment beginning on or after April 1, 2017. The CDTA is said to… – Continue reading
Ukraine is to sign a double tax agreement with Malaysia that will cap withholding tax rates on dividends, interest, and royalties. Under the deal, the withholding tax rate for dividends would be capped at 15 percent. A special rate of five percent would apply to dividends received by a company… – Continue reading
The Macau Special Administrative Region (MSAR) and China’s State Administration of Taxation in Beijing signed an additional protocol to the agreement to avoid double taxation and prevent tax evasion, officials said in Macau. The Additional Protocol, the third, according to the statement released by the Office of the Secretary for… – Continue reading
The absence of adequate data on the operations of businesses in the extractive sector continues to impede the GRA’s ability to fully implement Ghana’s transfer pricing policy. According to the Deputy Commissioner in charge of Policy Programs at the GRA, Edward Gyamerah, the issue makes it difficult to fully assess… – Continue reading
With an aim to avoiding double taxation, improving the investment environment for Taiwan, and increasing the attractiveness of foreign investment into Taiwan, the Ministry of Finance in recent years has focused on entering into tax treaties with other jurisdictions. Following tax treaties signed with Italy and Austria, Taiwan entered into… – Continue reading
On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The administrative law judge (ALJ) ruled that while the nondiscrimination provisions contained in Article 24 of the US-Germany Income… – Continue reading
Multinational companies doing business in Italy, Italian companies doing business abroad and non-resident companies which intend to invest in Italy may use the new international tax ruling procedure to reach an advanced agreement with the Italian Tax Authorities regarding the taxation of income derived from cross-border transactions. Recently, Legislative Decree… – Continue reading
The double taxation avoidance agreement between Singapore and France entered into force on June 1, 2016. Under the deal, withholding tax on dividends would be capped at 15 percent in general; and at five percent where the beneficial owner is a company that owns directly or indirectly at least ten… – Continue reading
On 20 April 2016, the Loan Market Association (“LMA”) updated its Standard Terms and Conditions for Par and Distressed Trade Transactions (Bank Debt/Claims) (“Standard Terms”) to include language that covers FATCA (as defined below) tax withholding on certain payments of US source FDAP income and, potentially, sale proceeds (as described… – Continue reading
India has asked the Netherlands to resume negotiations on amending their bilateral tax treaty as the government extends its efforts to plug loopholes in such accords to curb misuse. The Dutch tax treaty , which allows exemption from capital gains and a lower rate of tax on dividends, has led… – Continue reading
OECD BEPS guidance, outlining new standards for tax transparency and transfer pricing documentation, and the new union customs code, containing important changes to customs valuations, call for immediate action. Recent developments At the doorstep of a new era of tax transparency driven by the OECD BEPS project, the new Union… – Continue reading
Singapore and Cambodia have entered into a double taxation avoidance agreement to boost cross-border trade and investment between the two countries. The Agreement was signed on May 20, 2016, by Indranee Rajah, Singapore’s Senior Minister of State for Law and Finance, and Aun Pornmoniroth, Cambodia’s Senior Minister of Economy and… – Continue reading
NEW DELHI: Now that loopholes in the tax treaty with Mauritius have been plugged, the Indian government is gearing up to apply the same fix to its accord with Cyprus. Talks to amend the double taxation avoidance treaty are at an advanced stage and the two sides will soon exchange… – Continue reading
Transfer Pricing in China 2016, the latest publication from China Briefing and Dezan Shira & Associates, is out now and available for purchase through the Asia Briefing Bookstore. Transfer pricing is a reality for any multinational company. As a result of a globalized economy and increasing complexity in business models,… – Continue reading
Authorities answer OECD call to clamp down on corporate grey area of internal transfer pricing with proposal for tougher reporting standards China is mulling plans to tighten tax reporting requirements on multinationals operating in the country to help close a ¬massive global loophole. If the plan goes ahead, multinationals would… – Continue reading
The Irish Revenue has issued a brief explaining how the implementation of a most favored nation clause in Ireland’s tax treaty with Estonia will affect the tax treatment of royalties. Ireland’s Double Tax Convention (DTC) with Estonia became effective in 1999. It contains a provision whereby the tax treatment of… – Continue reading
With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading
THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading
The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading
On April 13 in Riga, Hong Kong’s Secretary for Financial Services and the Treasury K C Chan signed a comprehensive double taxation agreement between Hong Kong and Latvia. “This is the 35th CDTA that Hong Kong has signed with its trading partners and it signifies the Government’s ongoing efforts to… – Continue reading
The release of the so-called Panama Papers has shone a light on the secretive world of offshore tax havens and shown the exhaustive lengths that companies and wealthy individuals will go to in an effort to avoid paying tax. The trove of documents leaked from the Panama-based law firm Mossack… – Continue reading
Government has gazetted a Statutory Instrument (SI) to stop double taxation of Zimbabweans living and working in South Africa or South Africans working in Zimbabwe. The provision was gazetted last Friday. Part of the SI reads: “Subject to the provisions of article 16, 18 and 19, salaries, wages and other… – Continue reading
African governments should embrace meaningful bilateral investments agreements to foster sustainable economic growth on the continent. The call follows a report by the UN Economic Commission for Africa (ECA) on investment policies and bilateral investment treaties by Africa, indicating a huge gap between most of signed treaties and their actual… – Continue reading
The second Protocol to the double tax agreement between Singapore and the United Arab Emirates entered into force March 16, 2016, and will become effective from January 1, 2017, lowering withholding tax rates and amending permanent establishment rules. The protocol, which was signed in October 2014, revises the terms to… – Continue reading
As part of the Government’s crackdown on profit shifting by multinationals from the UK to low or no-tax jurisdictions, the Chancellor has announced in Budget 2016 a package of enhanced withholding tax measures which are designed to ensure that companies are not able to use intragroup royalty payments for avoidance…. – Continue reading
Retrospective amendments to domestic laws cannot override international treaties In a judgment that will have a far-reaching impact on double taxation issues, the Delhi High Court has held that Parliament cannot change the terms of an international treaty by bringing in amendments in the domestic law, and any such executive… – Continue reading
Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading
Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading
THE BUREAU of Internal Revenue (BIR) has released the details of its strategic plan reaching well into the next government, by which it intends to effect improvements in tax administration. BIR Commissioner Kim S. Jacinto-Henares on Feb. 15 issued Revenue Memorandum Order No. 6-2016 detailing the bureau’s Strategic Plan 2016-2020…. – Continue reading
Search giant Google – now a subsidy of Alphabet Inc. (NASDAQ:GOOG) – transferred around 11.7 billion euros ($13 billion) from its European operations to its accounts in Bermuda in 2014, in order to limit the tax burden on this income. This tax avoidance practice is often known as “Double Irish… – Continue reading
The decade-old arrangement allowed Alphabet to enjoy an effective tax rate of just 6 per cent on its non-US profits last year Google moved euro 10.7 billion euros ($12 billion) through the Netherlands to Bermuda in 2014, as part of a structure which allows it to earn most of its… – Continue reading
Double tax treaties enable competent authorities of the treaty partners to exchange important tax information necessary for implementing the treaty or the domestic laws on taxes of every kind and description imposed. For instance, exchanges of information may be made regarding tax avoidance by companies of the contracting states.Nevertheless information… – Continue reading
Documents released during the internet giant’s court battle with the US Internal Revenue Service over a possible $1.5bn in unpaid taxes detail a complex restructuring and a deal with Luxembourg that delivered Amazon multimillion-dollar savings Amazon is facing a landmark court ruling in the US that could prise open its… – Continue reading
The US Treasury Department has issued a revised version of the US Model Income Tax Convention (the 2016 Model). The Convention is used as a starting point in bilateral treaty negotiations with other countries and was last updated in 2006. The 2016 MTC, which was released on February 17, includes… – Continue reading
(Special) – If you’re planning on leaving Canada soon, don’t give up on contributing to your Registered Retirement Savings Plan (RRSP). If you become a non-resident of Canada, you can still contribute to an RRSP provided you still have accumulated contribution room available. “Your contribution room is determined by your… – Continue reading
EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading
Treasury is still fighting to keep a tax agreement out of parliament after a lobby group sued them over a pact it signed with Mauritius back in 2012. The double taxation avoidance agreement allows firms registered in the two countries to pay taxes in only one country. It also allows… – Continue reading
McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading
On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading
DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading
Hong Kong’s newly signed double tax deal with Russia is said to support the territory’s ongoing efforts to expand its tax treaty network with jurisdictions along “the Belt and Road.” The Belt and Road, or the Silk Road Economic Belt, is a Chinese Government economic development project, which is primarily… – Continue reading
In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading
Russia and the Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on avoidance of double taxation and prevention of fiscal evasion regarding profits taxes on Monday. The document was signed by Russia’s State Secretary, Deputy Finance Minister Yuriy Zubarev and the Secretary for Financial… – Continue reading
