US: IRS announces suspension of tax treaty with Russia
The US IRS has released Announcement 2024-26 regarding the suspension of the 1992 tax treaty with Russia. The suspension will take effect on 16 August, 2024, for taxes withheld at source and in respect of other taxes, and will continue until the two
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Spain confirms end of tax treaty with Kyrgyzstan
Spain’s Council of Ministers, through a statement, convened and approved an agreement recognising Kyrgyzstan's notice of termination of the 1985 tax treaty between Spain and the former Soviet Union on 11 June, 2024. This agreement was signed in
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Slovak Republic consults amending 2003 tax treaty protocol with Moldova
The Slovak Republic launched a public consultation on 30 May, 2024, regarding amending a protocol to the 2003 tax treaty with the Republic of Moldova. The protocol aims to align the treaty with BEPS and other OECD standards and prevent double
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Malaysia, Russia releases tax treaty updates
Malaysia and Russia signed a new income tax treaty on 17 May, 2024, which replaced the 1987 tax treaty between the two countries. As of now, the main measures of this new agreement are as follows: Scope of the taxes The tax treaty includes
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Slovak Republic, Moldova to sign tax treaty amendment
Moldova has issued Decree No. 1457 of 23 May 2024 in the Official Gazette, authorising the signing of a protocol to amend the 2003 tax treaty with the Slovak Republic. This will be the first amendment to the treaty and must be signed and ratified
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Netherlands approves amending protocol to income tax treaty with Germany
The Dutch Council of Ministers, on 8 May, 2024, granted approval to amending protocol to the 2012 income tax treaty with Germany. This protocol aims to enhance the tax treatment of individuals working remotely across borders. The treaty will
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UN: Tax Committee Discusses a New Combined Treaty Article on Services
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. The digital economy subcommittee in its workstream B has been considering the function and relevance of physical
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UN: Tax Committee Discusses Extractive Industry Tax and Other Issues
The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. The meeting is taking place in a global situation of inequality, as countries deal with challenges from increased
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US announces termination date of tax treaty with Hungary
On 29 December 2023, the U.S. IRS declared in the ‘Announcement 2024-05’ the effective date of the termination of the 1979 tax treaty with Hungary. The Government of the United States provided a diplomatic notification, dated 8 July 2022, to
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UN Tax Committee considers transfer pricing and treaty issues
The 27th session of the UN Committee of Experts on International Cooperation in Tax Matters took place from 17 to 20 October 2023. Subcommittees dealing with various areas of taxation presented updates to the Tax Committee on their
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UK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
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OECD: Peer Review Report on the Prevention of Treaty Shopping
On 21 March 2023 the OECD released the latest peer review results following assessment of the actions taken by each country to prevent tax treaty shopping under BEPS Action 6. The Fifth Peer Review Report on Treaty Shopping assesses the
See MoreJapan signs exchange of notes on arbitration with Denmark
On 5 November 2021, the Japanese Ministry of Finance announced an exchange of notes with Denmark regarding the entry into force of the arbitration provisions in the 2017 income tax treaty between the two countries. Due to the exchange of notes, the
See MoreSwitzerland: Federal Council adopts dispatch on amendments to DTA with Iran
On 23 October 2019, the Swiss Federal Council adopted the dispatch on the protocol of amendment to the agreement with Iran for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the minimum
See MoreSwitzerland: Federal Council adopts dispatch on protocol of amendment to DTA with Ukraine
On 9 October 2019, the Swiss Federal Council has adopted the dispatch on the approval of a protocol of amendment to the agreement between Switzerland and Ukraine for the avoidance of double taxation with respect to taxes on income and capital
See MoreUkraine signs amending protocol to DTA with UAE
On 24 July 2019, the Cabinet of Ukraine approved to sign an amending protocol to the Double Taxation Agreement (DTA) with United Arab Emirates (UAE). The provisions of the draft protocol fully comply with the requirements with the Organization for
See MoreUK: New protocol to double tax agreement with Israel
On 11 January 2019 the UK and Israel signed a protocol to update the double tax agreement between the two countries, incorporating tax treaty related recommendations of the OECD project on base erosion and profit shifting (BEPS). The protocol will
See MoreOECD: Guidance on synthesised texts clarifying the impact of the MLI
The OECD announced on 16 November 2018 that new guidance is available for the development of synthesised texts presenting a clear overview of the modifications by countries to their bilateral double tax treaties as a result of applying the
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