Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading
The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading
India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading
The OECD has set the minimum standards it requires from countries submitting Mutual Agreement Procedure (MAP) profiles, with only 41 countries currently having a completed profile, which will be used as a tool for resolving cross-border tax disputes The MAP falls under Action 14 on the Base Erosion and Profit… – Continue reading
The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading
The Cabinet today gave approval for signing and ratification of an agreement between India and Samoa for exchange of information to curb tax evasion. The agreement enables India and Samoa to provide assistance through exchange of information that is foreseeably relevant to the administration and enforcement of the domestic laws… – Continue reading
NEW DELHI: Aiming to curb tax evasion and avoidance, India has operationalised the Tax Information Exchange Agreement (TIEA) with Seychelles, one of the major sources of foreign investment into the country. The agreement will enable the authorities of both nations to provide assistance through exchange of tax and banking information,… – Continue reading
Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – 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
The recent EMEA Conference of Alliott Group, one of the world’s most established international associations of independent accounting and law firms, brought together tax professionals from 28 countries across the world to discuss Base Erosion & Profit Shifting (BEPS), a project led by the OECD and G20 whose Action Plan… – 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
India and Maldives today signed two agreements for exchange of information with respect to taxes, and for avoidance of double taxation of income derived from international air transport. The agreements were signed during the visit of President of Maldives Abdulla Yameen Abdul Gayoom to New Delhi. Gayoom is on a… – Continue reading
Ireland recently announced it will introduce a formal advance pricing agreement (APA) programme this year. Ireland has accepted and concluded bilateral APAs for many years although there have been no formal procedures to initiate an APA in Ireland. However, in light of comments made by an Irish Revenue official at… – Continue reading
The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD) plan to allow all countries to participate on an equal footing with OECD and G20 countries in the implementation of the OECD/G20 Base Erosion Profit Shifting (BEPS) plan. The framework announced by the OECD early… – Continue reading
Transfer pricing (TP) issues have never been such a critical part of the global economic agenda as they are today. Following the release of the report addressing Base Erosion and Profit Shifting (BEPS) in February 2013, OECD and G20 countries (including India) adopted a 15-point Action Plan to address BEPS… – Continue reading
Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according to a plan agreed to by the OECD today. The OECD’s framework for BEPS plan implementation, to be… – Continue reading
In the first part of this article, we talked about provisions of the Organisation for Economic Co-operation and Development’s (OECD’s) final report on Base Erosion and Profit Shifting (BEPS) Action Plan 14, which reflects the commitment of participating countries to implement substantial changes in their approach to dispute resolution in… – Continue reading
In our previous columns, we discussed the final reports of the Organisation for Economic Co-operation and Development (OECD) on the different action plans to address Base Erosion and Profit Shifting (BEPS). We will now focus on Action 14, which reflects the commitment of participating countries to implement substantial changes in… – Continue reading
India and the U.S. have reached an agreement to resolve more than 100 pending transfer pricing cases, one of the biggest deterrents for foreign investors planning an India foray, according to a government statement. Some more are expected to be resolved soon. Transfer pricing refers to the setting of the… – Continue reading
