OECD: Comments received on draft updates to Model Tax Convention
On 11 August 2017 the OECD published comments received on the draft 2017 updates to the OECD Model Tax Convention and commentary. The draft updates had been published for comment on 11 July 2017. Comments were received from the BEPS Monitoring
See MoreIndia: LOB clause under the India-Singapore tax treaty is not applicable to income taxed on an accrual basis in Singapore
Recently the Rajkot Bench of the Income-tax Appellate Tribunal in the case of: Alabra Shipping Pte Ltd, Singapore v. Income Tax Officer- held that the benefit of the India-Singapore income tax treaty was not to be denied to the taxpayer by
See MoreGhana: Treaty with Denmark boost Denmark’s investment in Ghana
Statistics from the Ghana Investment Promotion Centre (GIPC) reveal that direct investment from Denmark to Ghana in early 2014 amounted to over US$57.6million. The Finance Committee Report of Parliament also indicated that imports from Denmark to
See MorePeru: Notice on certificates of residence for claiming Double Tax Treaty benefits
On 3 July 2015 the Tax Authority of Peru issued Notice 094-2015 specifying certificates of residence status for claiming Double Tax Treaty benefits. According to the Peruvian law withholding will be required when an expense is accrued or when a
See MoreNetherlands – Reassigned authority for treaty-related LOB requests
The Netherlands has concluded a number of tax treaties containing a “Limitation of Benefits” (LOB) article that includes a “catch all” clause. The “catch all” clause allows taxpayers that initially would not qualify for the benefits of
See MoreIndia and US considering framework for resolving tax rows
India and the US could soon unveil details of a deal designed to resolve more than 100 outstanding tax disputes. The two sides almost finalized the outline of a mutual agreement procedure (MAP). Numerous discussions on the issue are said to have
See MoreNetherlands: Plans to update tax treaties with developing countries
The Netherlands has a plan to significantly improve tax transparency and to combat international tax avoidance by updating double tax treaties with low- and middle-income countries. The Netherlands has signed with more than 90 nations. The
See MoreItaly- Recent developments on MAPs
The ITA released on 5 June 2012 Circular 21/E/2012, to provide guidance to local tax offices on the application of Mutual Agreement Procedures (MAPs). According to the Circular the rules governing the MAP process have to be found in the respective
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