South Africa publishes synthesised text of tax treaty with Spain
The South African Revenue Service (SARS) has released a synthesized text of its tax treaty with Spain, reflecting updates from the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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Singapore, Kenya sign income tax treaty
Singapore’s government announced signing a new income tax treaty (DTA) with Kenya on 24 September 2024. This new DTA replaces the previous agreement signed on 12 June 2018 which never entered into force. The agreement establishes a 10%
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France details suspension and termination of tax treaty with Mali
The French General Directorate of Public Finance has provided guidance on the termination of the 1972 tax treaty with Mali. The treaty with Mali, signed on 22 September 1972 in Paris and effective from 1974, will be deemed terminated by France
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US: Senate fails to pass Taiwan double-tax relief bill
The US Senate failed to pass the legislation (H.R. 7024) featuring the US-Taiwan Expedited Double-Tax Relief Act on 1 August 2024. This legislation, known as the Tax Relief for American Families and Workers Act of 2024, aims to establish tax
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Finland revises guidance on avoiding double taxation for legal entities
Finland’s tax administration announced that it released an updated version of its guidance (Guidance number VH/3968/00.01.00/2024) aimed at eliminating international double taxation for legal entities on 1 August, 2024. The instructions apply
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Lithuania approves termination of tax treaty with Russia
The Lithuanian government approved a resolution to terminate the 1999 tax treaty with Russia on 26 June 2024. A law for the termination must now be submitted for parliamentary approval. Earlier, the Lithuanian government made public plans to
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OECD: Report on the Simplified and Streamlined Approach Under Amount B
On 19 February 2024 the OECD/G20 Inclusive Framework released the report on Amount B of Pillar One, following a previous consultation. The report sets out how jurisdictions can choose to apply the simplified and streamlined approach to qualifying
See MoreDominican Republic: DGII describes a guide regarding FTC
The Tax Authority has recently made a clarification through a Public Ruling, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. According to the letters, the maximum foreign income tax credit paid to a foreign
See MorePoland: MOF announces tax measures to attract foreign investment
On 14 June 2021, the Polish Ministry of Finance announced a new package of measures to encourage foreign investment in Poland. Accordingly, 95% tax exemption for dividends received by Polish holding companies after a one-year holding period,
See MoreUS: IRS and Treasury issue final regulations on foreign tax credits
On 12 November 2020, the Internal Revenue Service and Treasury published in the Federal Register providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax re-determinations, foreign tax credit
See MoreOECD: Seven peer review reports on BEPS Action 14 published
On 9 April 2020 the OECD published a further batch of reports in relation to stage 2 of the peer reviews of the implementation of Action 14 of the action plan on base erosion and profit shifting (BEPS). The minimum standard under BEPS action 14
See MoreChile: Tax authority describes foreign tax credits in case of dividends
The tax authority published a Letter No. 2625 of 16 October 2019 regarding credit for taxes paid abroad in case of dividends. It means where payment of dividends through a foreign intermediary, a foreign tax credit on the dividends is available
See MoreIndonesia: MoF issues restrictions on new foreign tax credit rules
The Minister of Finance (MoF) of Indonesia published a regulation No. 192/PMK.03/2018 regarding the implementation of tax credits on overseas income. PMK-192 is more comprehensive than the previous regulation regarding foreign tax credits (FTC).
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 MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreUK: Statistics on transfer pricing and diverted profits tax
On 1 August 2018 HMRC released a document showing the latest statistics relating to transfer pricing and the diverted profits tax (DPT). The transfer pricing rules and the DPT are seen by HMRC as an important part of the range of measures in place
See MoreUK: Double tax agreement with Colombia
On 2 November 2016 the UK and Colombia signed a double taxation agreement, during a state visit to the UK by the President of Colombia. The signing of the agreement is based on a shared commitment to increasing trade and investment between the two
See MoreUK: Double tax agreement with Algeria enters into force
The double taxation agreement between the UK and Algeria entered into force on 26 June 2016. The agreement was signed on 18 February 2015. The agreement will be effective in the UK from 1 January 2017 for withholding tax; from 1 April 2017 for
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