Minister, Embassy of Japan Mr. Isomata Akio asked India to exempt Japanese manufacturers, operating in India from withholding tax and Minimum Alternate Tax (MAT) so that these do not evolve into being one of the trade barriers and stagger Japan from becoming India’s largest trade partner in times to come. Japan investments and technology… – Continue reading
The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading
Companies with links to John George Russell are accused of entering into “tax avoidance” arrangements and are in a $3.5 million fight with the IRD. Russell – who developed a template that the Court of Appeal called a “blatant tax-avoidance scheme” – is a 79-year-old accountant being chased by the… – Continue reading
LONDON: Scottish explorer Cairn Energy plc today said it is working with the newly elected government to resolve a tax dispute that has stalled sale of its 10 per cent stake in Cairn India Ltd. “Cairn continues to seek resolution of the tax issue in India and will take all… – Continue reading
(MENAFN – Kuwait News Agency (KUNA)) A double-taxation avoidance agreement between Japan and Oman is expected to enter into force next month, the Japanese Foreign Ministry announced Monday.Japan notified Oman on Sunday of the completion of its internal ratification procedures for the treaty on the avoidance of double taxation and… – Continue reading
The Internal Revenue Service has updated the Withholding Foreign Partnership and Withholding Foreign Trust agreements as part of the process of implementing the Foreign Account Tax Compliance Act, or FATCA. FATCA, which was included as part of the HIRE Act of 2010, requires foreign financial institutions to report on the… – Continue reading
Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g., interest, dividends, royalties and other types of “fixed or determinable annual or periodical income,”… – Continue reading
Even if you beat long odds and win the lottery, you’ll have taxes to pay. It can be more challenging than you might think. Time and again, winners have trouble paying their taxes or get confused. The states vary in how they treat lottery winnings. A few states still don’t… – Continue reading
The British Property Federation (BPF) and the Chartered Institute of Taxation (CIOT) have welcomed an announcement from HM Revenue and Customs (HMRC) that institutional investors and companies with diverse ownership will be excluded from plans for a new capital gains tax (CGT) on UK properties sold by non-residents. The charge… – Continue reading
Canada and the UK on July 21, 2014, signed a protocol to their Double Tax Agreement that amends its withholding tax and information exchange provisions. The Protocol includes an exemption from withholding tax for payments of interest made in respect of loans between persons at arm’s length. The headline withholding… – Continue reading
As reported in Clyde & Co’s 2011 article titled ‘Chinese charterers deducting taxes from hire payments’ (click here to view), foreign vessel owners engaged in business with Chinese charterers have long faced China’s Enterprise Income Tax regime (“EIT”). That regime looks set to extend further into the international transportation sector… – Continue reading
The Board of Airline Representatives in Pakistan (BARIP), Karachi has urged the Federal Board of Revenue (FBR) to exempt certain categories of international passengers/travellers from payment of four percent withholding tax that include infants, transit passengers, diplomats, airline staff/supernumerary crew and Hajis from July 1, 2014-15. In a latest communication to… – Continue reading
Switzerland and Iceland have signed a new double taxation agreement (DTA) which lowers withholding tax rates and provides for the exchange of information in line with international standards. It will replace the existing DTA, signed in 1998. The treaty sets a withholding tax exemption for dividend payments from significant holdings… – Continue reading
The finance ministry will soon consider tax expert Parthasarathi Shome’s suggestions on possible instances where offshore sale of Indian assets need not be taxed here, said a finance ministry official. The Shome Committee had in its 2012 ‘Report on Retrospective Amendments Relating to Indirect Transfer of Indian assets’ suggested that… – Continue reading
Recently announced proposals by the Italian government to abolish withholding tax on loan interest payments and lift restrictions on direct lending to Italian companies are expected to give a major boost to the country’s loan market. The moves should make it much easier and cheaper for foreign banks and other… – Continue reading
David Murray’s financial system inquiry should push to remove withholding tax on non-residents’ deposits in Australian banks to help diversify the funding base of local banks and create more competition from foreign institutions. Next week’s report from the inquiry should also drive the development of a corporate bond market, back… – Continue reading
David Murray’s financial system inquiry should push to remove withholding tax on non-residents’ deposits in Australian banks to help diversify the funding base of local banks and create more competition from foreign institutions. Next week’s report from the inquiry should also drive the development of a corporate bond market, back… – Continue reading
Hong Kong (HKSAR) – The Secretary for Financial Services and the Treasury, Professor K C Chan, today (July 8) signed in Hong Kong an agreement with Korea for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income on behalf of the Hong… – Continue reading
The long awaited instructions for Form W-8BEN-E, Certification of Foreign Status of Beneficial Owner for United States Tax Withholding (Entities), were finally posted on the IRS website on June 24, 2014. Form W-8BEN-E will now be the most common form to be used by foreign entities to certify their status under both (i) Chapter 3 of… – Continue reading
“A government that robs Peter to pay Paul, can always count on the support of Paul”– George Bernard Shaw. Well, the UPA government certainly did a Peter to multinational companies operating in India by hiking withholding taxes from 10% to a good 25% in the 2013 budget. Who is the… – Continue reading
Property-buyers and expats in Spain should note that a new Double Taxation Convention between the UK and Spain, which was signed in London on 14th March 2013, came into force in June 2014. Richard Way, Editor of www.OverseasGuidesCompany.com, publishers of www.SpainBuyingGuide.com said: “From June 12th, rules for withholding tax on… – Continue reading
Zambia was withholding $600 million (R6.3 billion) in VAT refunds owed to copper mining companies and would repay it only when they produced import certificates from destination countries, Mining Minister Christopher Yaluma said yesterday. The government started last year to enforce the 2008 requirement intended to curb tax avoidance. However,… – Continue reading
With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading
DELHI – After classifying Cyprus as a “notified jurisdiction” last November and suspending double taxation avoidance agreement (DTAA) benefits, India may soon revise its DTAA with Cyprus and restore a 10 percent withholding tax rate in light of recent progress in tax information sharing. Since the two countries signed a… – Continue reading
The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading
On June 5, 2014, the Court of Justice of the European Union handed down a joint ruling concerning two Dutch companies’ objections to the imposition of withholding tax on dividends paid to their respective holding companies based in the former Netherlands Antilles. In X BV, TBG Limited vs Staatssecretaris van Financien (C-24/12… – Continue reading
India is said to be seeking a revision to its 1994 double tax agreement with Cyprus before the territory can be declassified as a notified jurisdictional area. In November of last year, the Indian Government invoked powers under Section 94A of the Indian Income Tax Act (ITA) 1961 to levy… – Continue reading
HANOI – On May 7th, New Zealand’s double tax agreement (DTA) with Vietnam went into effect. The DTA agreement was originally signed on August 5, 2013. New Zealand’s Revenue Minister, Todd McClay, stated that “the new double tax agreement which was signed in August 2013 brings our network of tax… – Continue reading
India amended its domestic tax law for transactions with taxpayers of certain tax jurisdictions, as an anti-avoidance measure. The amendments involving transactions made in Cyprus include a temporary 30% withholding tax for all transactions between India and Cyprus in place since March. Under the double tax treaty between India and… – Continue reading
CALGARY – A Calgary-based United States tax expert has recommended to the federal government that Canada follow the lead of other countries and include certain Canadian trusts within the definition of organizations subject to reporting under the recent Intergovernmental Agreement between the Canada and the U.S. “This would eliminate the… – Continue reading
Course summary: Justin Bender of PWL Capital and Dan Bortolotti of PWL Advisors explain the ins and outs of foreign withholding tax on U.S. and international equity index funds and ETFs. INTRODUCTION Canadian investors get an enormous benefit from diversifying their portfolios with US and international stocks. But this benefit… – Continue reading
A £100m charity tax avoidance scheme similar to the Cup Trust has been defeated at a tax tribunal by HM Revenue & Customs.According to the judgment handed down this week by the first tier of the tax tribunal, the Bluebox scheme used a method where government bonds were given to… – Continue reading
Up to December 31, 2013, Mexico did not tax dividend payments. However, the Mexican Income Tax Law (“MITL”) that entered into force on January 1, 2014 established a new 10 percent withholding tax on the gross amount of dividend payments made by legal entities resident in Mexico for tax purposes… – Continue reading
Exempting domestic currency government bonds from withholding tax is long overdue in much of South and East Asia as the move would have a significant and beneficial economic impact. The mature economies in Europe and North America (and also Japan, Hong Kong and Singapore) no longer withhold tax on government… – Continue reading
Three members of Take That are reported to have invested in a tax avoidance scheme – so will they join our festival line-up of stars who, through schemes or leaving the country, have avoided tax? Whether by moving country or through schemes and accountants, celebrities finding ways to avoid tax… – Continue reading
In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping. Eleven months later, in Budget 2014, the Government invited comments on a proposed domestic anti-treaty abuse rule. This article briefly reviews developments arising between the two budgets and provides high level comments in… – Continue reading
NEW DELHI: The Indian Tax authorities and the Swiss government could be headed for a showdown over what the Indian side regards as lack of co-operation from the Alpine country over access to information on bank accounts. Last week Finance Minister P Chidambaram wrote to his Swiss counterpart – officials… – Continue reading
United States taxpayers make large interest payments to the top four technology firmsfor the $163 billion in US government debt the companies own and shelter in tax-freeoffshore accounts. Apple, Cisco Systems, Google, and Microsoft legally hold $124 billion in US Treasury securities and $39 billion in US government agencydebt in accounts overseas, allowing them to avoid the 35… – Continue reading
BEIJING – Wholly Foreign Owned Enterprises (WFOEs) are able to repatriate funds out of China in a variety of forms, for which tax implications vary according to the form of repatriation used and the Double Taxation Agreement (DTA) in place between China and the recipient country. The four most commonly… – Continue reading
The Canada-British Virgin Islands (BVI) tax information exchange agreement (TIEA) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in article 13 of the agreement. The BVI is now party to 25 TIEAs. The BVI-Canada TIEA is… – Continue reading
February 17 — New Zealand Revenue Minister Todd McClay on February 10 announced that the agreement for the avoidance of double taxation between New Zealand and Papua New Guinea entered into force on January 21, 2014. The two countries signed the tax treaty on October 29, 2012 (216 International Tax… – Continue reading
The Government on Tuesday said efforts were being made to find mutually acceptable solution to address India’s concerns while revising the tax treaty with Mauritius. The Government has proposed to review the India-Mauritius Double Taxation Avoidance Convention (DTAC) to incorporate amendments to the pact for prevention of treaty abuse and… – Continue reading
Feb 11 (Reuters) – Austria signalled on Tuesday flexibility on exchanging cross-border bank account data with fellow European Union members even absent a final EU accord with Switzerland. “As far as banking secrecy for foreigners goes, it is important for us that there are similar accords with neighbours like Switzerland… – Continue reading
A new India-Cyprus double tax avoidance agreement (DTAA) or tax treaty, inches closer to finalisation. The delegates of the two countries are slated to meet in early-mid March to tie up the loose ends. While the revised treaty will contain more stringent provisions relating to exchange of information, it is… – Continue reading
