Italy: Council of Ministers approve amending protocols on frontier workers under tax treaty with Switzerland
 Italy approved a draft law on 19 May 2025 to ratify amendments to agreements from 2024, modified by the 1978 and 2015 protocols. Italy’s Council of Ministers has approved a draft law on 19 May 2025, which ratifies the amending protocol
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Azerbaijan, Kyrgyzstan tax treaty enters into force
The income tax treaty between Azerbaijan and Kyrgyzstan came into force on 8 January 2025. Signed on 24 April 2024, this agreement is the first tax treaty established between the two nations. As per the agreement, withholding taxes are applicable
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Paraguay, Spain income tax treaty enters into forceÂ
The income tax treaty between Paraguay and Spain took effect on 14 October 2024. This agreement aims to enhance economic relations, encourage investments, and enhance bilateral cooperation in tax matters between the two countries. It seeks to
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Argentina, Turkey tax treaty enters into forceÂ
The income tax treaty between Argentina and Turkey came into effect on 13 September 2024. The treaty applies from 1 January 2025. Signed on 1 December 2018, this treaty is the first between the two nations. Earlier, Argentina ratified the tax
See MoreUN: Guide on Tax Treaties for Investment Policymakers
On 13 February 2024 UNCTAD released a guide with the title Double taxation treaties: What investment policymakers need to know. The guide deals with the aspects of double tax treaties that are important for investment policymakers to understand, and
See MoreOECD: Fourth Peer Review Report on Prevention of Tax Treaty Abuse
On 21 March 2022 the OECD released the fourth peer review report on tax treaty abuse under Action 6 of the action plan on base erosion and profit shifting (BEPS). The report looks at the measures that member countries of the OECD’s
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreOECD: 2020 Peer Review Report on Treaty Shopping
On 1 April 2021 the OECD released the latest annual peer review report on adoption of measures against treaty shopping. The report on Action 6 of the OECD project on base erosion and profit shifting (BEPS) noted that abuse of double tax
See MoreOECD: Tax issues for cross border workers during the COVID-19 crisis
On 7 April 2020 the OECD published on its website guidance on tax issues relating to cross-border workers during the crisis. As a result of travel restrictions and quarantine requirements many cross-border workers cannot go to the country where
See MoreUK: Double tax treaty with Lesotho takes effect
The double tax treaty between the UK and Lesotho takes effect in relation to UK corporation tax for financial years beginning on or after 1 April 2019. The treaty was signed on 3 November 2016 and entered into force on 18 September 2018. Permanent
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 MoreUK: Double Tax Agreement with Guernsey in force
The comprehensive Double Taxation Agreement and Protocol between the UK and Guernsey was signed on 2 July 2018 entered into force on 7 January 2019. When the agreement is in effect in relation the 1955 Arrangement between Guernsey and the UK for the
See MoreUK: Double tax treaty with Isle of Man enters into force
The double tax treaty between the UK and the Isle of Man entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and the Isle of Man for the avoidance of double taxation which ceases to have effect from the
See MoreUK: Double tax treaty with Jersey enters into force
The double tax treaty between the UK and Jersey entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and Jersey for the avoidance of double taxation which ceases to have effect from the dates on which the
See MoreUK: Provisions of updated tax treaty with Cyprus
The updated UK-Cyprus Double Taxation Agreement (DTA) signed on March 22 2018Â aligns the provisions more closely with the OECD Model. Withholding tax The new treaty when in effect will provide for zero withholding tax on dividends unless they are
See MoreUN releases the 2017 update to the UN Model Convention
The UN released the 2017 update to the UN Model Convention at the 16th Session of the UN Committee of Experts in New York held from 14 to 17 May 2018. The updated Convention contains a new preamble emphasizing that tax treaties should not create
See MoreOECD: 2017 edition of the Model Tax Convention released
On 18 December 2017 the OECD released the 2017 edition of the Model Tax Convention. This edition incorporates measures outlined in the final reports from the action plan on base erosion and profit shifting. The new edition reflects work on BEPS
See MoreUK: Statistics on non-domiciled taxpayers
On 31 August 2017 HMRC released statistics on non-domiciled taxpayers in the UK from 2007/08 to 2014/15. This is the first time that comprehensive statistics on non-domiciled taxpayers in the UK have been published and this will now become an annual
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