The UK and Luxembourg Signed A New Double Tax Treaty
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. ... - Continue reading
Category: Withholding Tax
Ireland: Aviation Finance & Leasing 2022
Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading
Q&A: tax issues for private equity funds in Cayman Islands
Under current Cayman Islands law, there are no Cayman Islands taxes on income or gains of the private equity fund (PE fund) or on gains on dispositions of shares or partnership interests, and distributions made by a PE fund will not be subject to withholding tax in the Cayman Islands. ... - Continue reading
Requests for confirmation, tax treaty relief applications and tax sparing applications
IN 2021, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order (RMO) 14-2021 and Revenue Memorandum Circular (RMC) 77-2021, which streamlined the procedure for the availment of benefits under the applicable tax treaty. ... - Continue reading
UAE and Israel Sign Tax Treaty
According to the Israeli Government’s announcement, the treaty is based on the Organisation for Economic Co-operation and Development Model Tax Convention on Income and on Capital (OECD Model) and covers areas including double-taxation, non-discrimination, exchange of information and anti-avoidance. ... - Continue reading
Often Overlooked Exception to Withholding and Reporting Requirements under FATCA
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. ... - Continue reading
Ten-year tax incentives granted to special technology zones
The government has granted a comprehensive duty and tax incentives for a period of 10 years to investors operating in the proposed special technology zones (STZs), sources in the Federal Board of Revenue (FBR) said on Monday. The incentives also include immunity from explaining the source of funds to be… – Continue reading
Cyprus: Cyprus – Russia Double Tax Treaty
Cyprus strikes a deal on Double Tax Treaty with Russian Government The Republic of Cyprus and Russia had entered into a Double Tax Treaty (DTT) in 1998 in a joint effort to avoid the double taxing of income and capital generated in Cyprus, in order to promote the economic cooperation between the two countries. Since its introduction, the DTT has been the catalyst for Russian investment in Cyprus, being an attractive jurisdiction with regards to its tax benefits. ... - Continue reading
Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company
The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading
FBR mulls online feature to show WHT deduction
The tax authority of Pakistan to introduce an online option as tax reform. ... - Continue reading
POGOs must settle all tax liabilities — Dominguez
Philippine offshore gaming operators (POGO) to pay all tax liabilities before being allowed to operate again, says Finance secretary Carlos Dominguez. ... - Continue reading
Nigeria: Tax Appeal Tribunal Holds That Tax Exemptions Will Not Be Granted Unless All Conditions Precedent For Its Grant Are Fulfilled
Light on the court case dated 23rd December 2019. ... - Continue reading
FBR receives 10,000 income tax returns in virus downturn
10,000 income tax returns received by the Federal Board of Bureau during the COVID-19. ... - Continue reading
Norway proposes new withholding tax on some related-party payments
Authorities of Norway come up with new withholding tax rules. ... - Continue reading
Tax collection on cash withdrawal dives 63 percent
This sharp decline was because of the exemption from the levy given to active taxpayers. ... - Continue reading
Norway consulting on new withholding tax on interest, royalties
Norway’s Finance Ministry is consulting shareholders on a new proposal to introduce withholding tax on certain payments to non-resident related parties. ... - Continue reading
India Budget 2020: The key takeaways
Here are some important tax proposals for India's 2020 Budget. ... - Continue reading
Tax on dividend income grows 30pc
Pakistan's officials state 30 percent increase in tax collection on dividend income. ... - Continue reading
Hong Kong announces entry into force of Cambodia, Estonia tax treaties
New tax treaties into force ... - Continue reading
Singapore, Tunisia tax treaty enters into force
Singapore and Tunisia join forces in favour of tax reform. ... - Continue reading
US IRS publishes final tax regulations on dividend equivalents
Final tax laws published. ... - Continue reading
Tax obligations of permanent establishments
The Philippines generally follows the “source of income” rule in identifying the income that are taxable to corporations in the Philippines. ... - Continue reading
Ukraine: The Parliament Of Ukraine Has Ratified Documents Amending Double Taxation Treaties
On 30 October 2019, the Parliament of Ukraine ratified Protocols amending double taxation treaties with the United Kingdom and Cyprus. ... - Continue reading
Balanced tax collection system soon: minister
Punjab Finance Minister Makhdoom Hashim Jawan Bakht has said that the government was making efforts for unification of taxes and harmonisation in revenue collection in all four provinces while clarifications would be made on the tax related litigations and GST on services related matters. The minister chairing a review meeting… – Continue reading
EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to a Gibraltar companies from withholding tax
The Advocate General (AG) in an opinion issued 24 October (Case C-458/18) stated that a company incorporated in Gibraltar and subject to Gibraltar corporation tax cannot be considered to be a “company of a Member State” within the meaning of the parent-subsidiary directive (Directive 2011/96). ... - Continue reading
Tax department posts 32pc growth in revenue in 1Q
A regional tax office posted 32 percent jump in revenue collection to Rs26.43 billion in the first quarter of the current fiscal year as tax rates on non-compliance increased during the period, sources said on Wednesday. Revenue collection by the Regional Tax Office (RTO)-II Karachi amounted to Rs19.98 billion in… – Continue reading
POGOs’ tax compliance improves
The tax compliance of online gaming operators and their service providers continue to show improvements every month amid the strict enforcement activities of the government, a tax official said. The Bureau of Internal Revenue (BIR) initially reported that its preliminary income tax collection from Philippine offshore gaming operators (POGO) foreign… – Continue reading
BIR Officials: Congress not inclined to lift Bank Secrecy
“The suggestion has been brought up many times before and lawmakers with the support of the business community rejected it,” said a revenue regional director who declined to be named. He recalled that many congressmen even protested when the BIR in 2014 tried to require taxpayers to include in their… – Continue reading
India: No Withholding Tax Applicable On Arbitral Award
The Delhi High Court ("Court") in Glencore International AG v. Dalmia Cement (Bharat) Limited has held that amounts paid to a non-resident pursuant to an international arbitration award would not be subject to withholding tax in India. ... - Continue reading
BIR warns delinquent POGOs anew
The Bureau of Internal Revenue (BIR) said that service providers for Philippine offshore gaming operators (POGO) must cooperate and comply with the tax authorities to avoid revenue losses once they become subject for closure. BIR Commissioner Caesar R. Dulay said that POGO service providers should be prepared to incur millions… – Continue reading
Worldwide: Financial Institutions And Personal Data
Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading
Uganda: Don’t Make Up Losses To Avoid Tax
Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading
BIR padlocks main office, 2 branches of tax-dodging POGO service provider
The Bureau of Internal Revenue (BIR) padlocked simultaneously Wednesday the main office and two branches of one of the biggest Philippine Offshore Gaming Operator (POGO) service providers in the country for alleged failure to register and pay the corresponding deficiency taxes amounting to P2 billion. Shuttered were the headquarter of… – Continue reading
