SOUTH African companies with operations elsewhere in Africa, such as telecommunications giant MTN, have reason to breathe a little easier having earned a tax respite, albeit considered minor by tax experts. The Treasury has made a concession on the proposed repeal of foreign tax credits for fees on services provided… – Continue reading
A new Protocol to the income tax treaty between Indonesia and the Netherlands was signed 30 July 2015 and will be effective 31 days after formal approval and ratification by both governments. Among the measures contained in the Protocol are revisions to the withholding tax rates on dividend payments. The… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the… – Continue reading
The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
SOON, THAILAND will no longer have mere transfer-pricing guidelines in the form of Departmental Instruction Paw 113/2545, but will instead put into effect a transfer-pricing law, the draft of which was approved by the Cabinet in May. Taxpayers will of course be required to abide by the new law. There… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
Ireland will introduce a new lower tax on intellectual property to keep and win more overseas investment as the government phases out a controversial loophole known as the “Double Irish.”, reports Bloomberg. The new knowledge development box will tax profits from patented innovations such as technological and pharmaceutical developments at… – Continue reading
The number of letter box companies in the Netherlands continues to grow, despite both mounting criticism and tougher rules aimed at combating tax evasion, the Volkskrant said on Tuesday. The number of letter box firms – so called because they only exist on paper – rose 17% to 14,425 over… – Continue reading
Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading
Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits offshore, a sufficient presence ”on the ground” can pull sales income (and… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
Spanish prosecutors have dropped all tax fraud charges against FC Barcelona’s Argentinian star Lionel Messi, but will pursue the case against his father. Jorge Horacio Messi and the footballer were accused of defrauding Spain’s tax office by not paying €4m (£2.9m, $4.5m) due in taxes between 2007-09. If convicted, the… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading
The OECD’s final package of proposals for reforming the international system for taxing companies brings to an end the two-year BEPS project led by the OECD and other G20 countries which also included participation by representatives of developing countries, business, academia and NGOs. Developing the BEPS, or Base Erosion and… – Continue reading
By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading
The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading
The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on… – Continue reading
The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to legal persons tax and that qualify as founders or third-party beneficiaries of so-called… – Continue reading
MBABANE – City Press has alleged that the Swazi government has been robbed of billions of Emalangeni in the mining deal of iron ore at Ngwenya mine as the funds were siphoned off to the Seychelles in an abusive transfer pricing scheme. Financial statements of Shanmuga Rethenam’s companies have revealed… – Continue reading
Thousands of Australians head offshore each year to expand their horizons and a lucky few will fund their adventure by working overseas. Some may live overseas and work for an extended period. There can often be confusion about the tax implications for taxpayers who take advantage of such offshore opportunities…. – Continue reading
Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading
BHP Billiton has defended the use of a Singapore marketing hub to minimise its tax payments, saying most of its Australian profits continue to be taxed in its home country. The resources giant, which came under fire earlier this year over allegations of tax avoidance, says its global adjusted effective… – Continue reading
Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading
Labor has rejected co-operating with the Coalition on boosting the goods and services tax, whatever the outcome of next year’s tax white paper and negotiations with the states. Addressing the Australian Financial Review tax summit in Sydney, Labor treasury spokesman Chris Bowen said while any GST rise would be permanent,… – Continue reading
In 28 August 2015, the Chinese State Administration of Taxation issued an Announcement for Granting Tax Treaty benefits to non-residents. The Announcement proposes a new system for granting tax treaty benefits where there pre-approval of the tax authorities is no longer required for withholding tax agents to apply reduced tax… – Continue reading
(Corrects first and sixth paragraphs to make clear Intertrust does not provide tax advice) (Reuters) – Intertrust, which provides tax and regulatory compliance services to 17,000 companies, said on Monday it will seek an initial public offering (IPO) of shares on the Euronext stock exchange. The Amsterdam-based company did not… – Continue reading
SINGAPORE first entered a double taxation agreement (DTA) with Thailand in 1975. After 40 years, Singapore and Thailand signed a new DTA on June 11, 2015. The newly signed DTA has not yet been ratified by either country, and will go into force after it is. Below are some of… – Continue reading
In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading
Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading
Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading
All eyes are on how much taxes the British retailer Tesco Group will pay to the South Korean government after its profit of more than 5 trillion won (US$4.21 billion) with the sale of Homeplus. Industry sources say that the company will not have to pay taxes at all, or… – Continue reading
The Thai Board of Investment introduced a new program to encourage the location of headquarters in Thailand. Among the incentives are provisions providing relief from corporate income tax (0% on non-Thai source income from services, royalties, and dividends, and 10% on certain Thai source income) for a period of 15… – Continue reading
On August 25, 2015, the People’s Republic of China and Taiwan signed an Agreement for the Avoidance of Double Taxation regarding Taxes on Income (“the DTA”), which will enter into force when the legal procedures have been completed. The DTA’s highlights: 1. Permanent establishment (“PE”) specifications The DTA establishes a… – Continue reading
Negotiations took place, on 2 July 2015, at the Ministry of Finance of the Republic of Cyprus, concluding a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income, when it expires. The agreed protocol, when… – Continue reading
On April 1, 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 December 8, 1998. At the time the original DTA was concluded, dividends arising in South Africa were not subjected to South… – Continue reading
On September 8, 2015 the Cypriot Ministry of Finance published an announcement titled: “Conclusion of a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income between the Republic of Cyprus and the Government of Ukraine… – Continue reading
Intangible assets in the oil and gas industry have become incredibly valuable. Taxpayers need to understand how to manage compliance to mitigate their transfer pricing risks What do recent Western economic sanctions against Russia; the US’ growing energy independence; and ultra-deepwater oil and gas (O&G) discoveries off the coast of… – Continue reading
Malta’s tax legislation provides for a number of benefits which can be derived by companies and their shareholders. The tax rules can lead to a tax burden in Malta which is significantly reduced or completely eliminated in certain cases, and the following are some of the key tax benefits which… – Continue reading
Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Zambia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Kenya for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
In the overview of tax treaties as published on the website of the Irish Revenue, the Irish Revenue has published a statement announcing that the Convention between the Government of Ireland and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… – Continue reading
Improvement of the e-management system for value added tax The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on 16 July 2015. The law in its main part came into… – Continue reading
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – 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
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
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
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
