Netherlands updates list of developing countries for tax treaty purposes in 2025
The Dutch Tax Authority has published its annual list of countries designated as developing nations under Article 6 of the 2001 Double Taxation Prevention Decree (Bvdb 2001) for 2025. Since 1 January 2017, the Netherlands has applied specific
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UN Tax Committee Discusses Manual on the Negotiation of Bilateral Tax Treaties
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workplan for updating the Manual on the Negotiation of Bilateral Tax Treaties. The relevant subcommittee presented its planned workstreams for
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UN: Relationship of Tax, Trade and Investment Agreements
The UN Tax Committee at its meetings from 18 to 21 October 2022 discussed an update of the work on the interaction of tax, trade and investment agreements. The Subcommittee on the Relationship of Tax, Trade and Investment Agreements is mandated
See MoreCanada CRA publishes a notice regarding the effect of MFN provisions with Lithuania
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on the Most Favoured Nation (MFN) provision of the CanadaāLithuania Income Tax Convention with respect to certain royalties. Effective January 1, 2019, the
See MoreCanada: CRA publishes a notice regarding the effect of MFN provisions with Latvia
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on Most Favoured Nation (MFN) provision of the CanadaāLatvia Income Tax Convention with respect to certain royalties. Effective January 1, 2018, the
See MoreSouth Africa: SARS issues ruling on MFN clause in a treaty with Sweden
On 1 March 2017, the South African Revenue (SARS) issued a private binding ruling no. BPR 267 regarding dividends tax and the āmost favoured nationā clause in a tax treaty concluded with Sweden. The ruling determines whether dividends tax must
See MoreUK, Estonia MFN provision: 0% withholding tax on royalty income
Paragraph 7 of the Exchange of Notes to the 1994 Double Taxation Agreement (DTA) contains a āMost Favoured Nationā (MFN) provision relating to royalties (Article 12). It gives UK residents access to any lower rates agreed by Estonia in
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and India of 1992 activated
The most-favored-benefit clause of the Income and Capital Tax Agreement between France and India of 1992 was activated. As a result, the applicable tax rate and the amount of the withholding tax on dividends, interest, royalties and remunerations as
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and Estonia of 1997 activated
The Income and Capital Tax Treaty of 2014 between Estonia and Luxembourg activated the MFN clause of the protocol to the treaty between France and Estonia of 1997. As a result, interest paid to any kind of loan of whatever kind granted by a bank, as
See MoreMFN clause of the protocol to the Egypt – France Income and Capital Tax Treaty (1980) (as amended through 1999) activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. As a result, the MFN clause in article II of the protocol to the Egypt -
See MoreMFN clause of the protocol to the Income and Capital Tax Treaty between France and Chile of 2004 activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. Accordingly, the MFN clause in paragraph 6 of the protocol to the Chile
See MoreMost favoured nation clause of the protocol to the Bolivia – France Income and Capital Tax Treaty (1994) activated
The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties. Accordingly, the MFN clause in article 5 of the protocol to the Bolivia
See MoreSpain-Estonia MFN clauses under DTA activated
The Spanish Ministry of Finance and Public Administration published a letter on 14 June 2016 addressed to the Estonian Minister of Finance. The letter activates the most-favoured-nation (MFN) clauses included in theĀ Estonia - Spain Income and
See MoreIndia: Payments for BSP link services are not āFees for Technical Servicesā under India-France tax treaty by virtue of MFN clause
The Income Tax Appellate Tribunal (ITAT) provided a decision on 11 June 2014 in the case of DDIT v. IATA BSP India Ā that payment towards BSP Link services is not fees for technical services (FTS) by virtue of the most favored nation (MFN) clause in
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