Double Taxation Treaties

Morocco: Finance Law 2017 gazetted

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The Government of Morocco published the Finance Law 2017 on 12th of June 2017 in the official gazette. The law provides an anti-avoidance rule, a tax relief in case of dividends, interest, and rental income for real estate collective investment undertakings under some conditions, A 3 years VAT postponement for the acquisition of equipment developed for investment projects of at least MAD 100 million according to an investment agreement with the government for both new and remaining corporations, a tax relief extends for five years for profits resulting from export operations to indirect exporters conditioning that exporters do not stayed inside the free zones. Additionally, the conditions for tax exemption in case of rental income are: the only activity of the undertaking is the lease of immovable features used for professional purposes, no less than 85% of the annual rental profits are distributed and the assets added to the undertaking are measured by a certified contributions assessor and kept for at least 10 years. The Finance law 2017 applies from 1st January 2017 and it is available in French language.

Italy: Draft law ratifying DTA with Romania approved

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The Senate of Italy approved the draft law ratifying the Double Taxation Agreement (DTA) with Romania on 4 May 2017. Once in force and effective, the treaty will replace the existing DTA of 1977.

Portugal: DTA with Ethiopia enters into force

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The Double Taxation Agreement (DTA) between Ethiopia and Portugal entered into force on 9 April 2017. The agreement provides for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

Saudi Arabia: DTA with Egypt approved

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On 1 May 2017, the cabinet of Saudi Arabian approved the Double Taxation Agreement (DTA) with Egypt for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

Canada: DTA negotiations with Switzerland

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The Finance Department of Canada has declared that negotiations to update its Double Tax Agreements (DTA) with the Swiss Confederation will be held in June 2017. The main objective of this release is to ensure that persons whose interests are affected have an opportunity to inform the Government of any particular issues of double taxation that might be resolved in a tax treaty. The Government is particularly interested in gathering knowledge of any difficulties encountered by Canadians under the German tax system so that these issues might be considered in negotiations. Persons are invited to give their comments regarding this negotiations and send it to the Finance Department.

Canada: DTA negotiations with Germany

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The Finance Department of Canada has declared that negotiations to update its Double Tax Agreements (DTA) with Germany will be held in June 2017. The main objective of this release is to ensure that persons whose interests are affected have an opportunity to inform the Government of any particular issues of double taxation that might be resolved in a tax treaty. The Government is particularly interested in gathering knowledge of any difficulties encountered by Canadians under the German tax system so that these issues might be considered in negotiations. Persons are invited to give their comments regarding this negotiations and send it to the Finance Department.

Australia signs MLI to prevent tax avoidance

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Australia has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”). The Minister for Trade, Tourism and Investment, Mr. Steven Ciobo MP, signed the Convention for Australia at a ceremony hosted by the Organisation for Economic Cooperation and Development (OECD) in Paris on 7 June 2017.  67 other jurisdictions also signed the Convention, including 35 of Australia’s bilateral tax treaty partners.

The Convention is a key outcome of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, which aims to ensure that multinationals pay tax in the jurisdiction where economic value is created or added.

Once in force, the Convention will modify most of Australia’s bilateral tax treaties to implement new integrity rules that will help prevent exploitation for tax avoidance purposes and improve tax treaty-based dispute resolution mechanisms.

The Convention will enter into force after signatories have completed their domestic requirements and deposited their instruments of ratification with the OECD. Legislation will be introduced into the Australian Parliament as soon as practicable to give the Convention the force of law in Australia.