OECD: Comments Received on Changes to the Commentary to Article 5
On 22 January 2024, the OECD published comments on proposed amendments to the commentary to Article 5 in relation to an alternative provision on activities in connection with the exploration and exploitation of natural resources. The additional
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Tax Treaty Brief: January 2024
Germany and Sweden On 31 December 2023, the amending protocol to the Double Taxation Agreement (DTA) between Germany and Sweden entered into force. In general, the provisions of the protocol apply from 1 January 2024. Oman and Russia On
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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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Tax Treaty Brief: December 2023
Belarus and Equatorial Guinea On 28 November 2023, Mr. Alexander Lukashenko, the President of Belarus signed a decree that grants approval to negotiate and sign of a Double Taxation Agreement (DTA) with Equatorial Guinea. Moldova and
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Cyprus and France sign the DTA to strengthen economic ties
On 11 December 2023, the Convention for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, and its Protocol between the Republic of Cyprus and the French Republic, was signed in
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Tax Treaty Brief: November 2023
Croatia and Cyprus On 27 October 2023, Cyprus ratified the Double Taxation Agreement (DTA) with Croatia. Cambodia, Congo (Dem. Rep.), Senegal, Sri Lanka, and Turkey On 26 October 2023, the Turkish Parliament approved the Double Taxation
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OECD Releases Information and Statistics on Mutual Agreement Procedures
On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line
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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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Tax Treaty Brief: October 2023
Andorra and Croatia On 28 September 2023, the Croatian parliament approved the ratification of the Double Taxation Agreement (DTA) with Andorra. Iran and Ukraine On 26 September 2023, Ukraine has published Letter No. 72/14-612/1-114650
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Tax Treaty Brief: September 2023
Bangladesh and Hong Kong On 30 August 2023, the Govt. officials from Bangladesh and Hong Kong signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
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Hong Kong and Bangladesh enter into tax pact
On 30 August 2023, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, on behalf of the Hong Kong Special Administrative Region Government signed a comprehensive avoidance of double taxation agreement (CDTA) with Bangladesh.
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Tax Treaty Brief: August 2023
Albania and Slovak Republic On 26 July 2023, the Council of Ministers in Albania approved the draft legislation for the ratification of the Double Taxation Agreement (DTA) with the Slovak Republic. Germany and Switzerland On 26 July
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OECD: Facilitating the Use of Treaty Exchanged Information for Non-Tax Purposes
Sharing of treaty-exchanged information with relevant law enforcement agencies for non-tax purposes helps to combat illicit financial flows (IFFs), money laundering and corruption. Institutions often face operational challenges in implementing this
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Tax Treaty Brief: July 2023
Cyprus and Netherlands On 30 June 2023, the Double Taxation Agreement (DTA) between Cyprus and the Netherlands entered into force. The DTA contains withholding tax rates for Dividends 0% for at least 5% capital holding; otherwise, 15%,
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Tax Treaty Brief: June 2023
Slovenia and Switzerland On 30 May 2023, Slovenia and Switzerland officially signed an amending protocol to update the Double Taxation Agreement (DTA) between the two nations. The primary objective of this protocol is to ensure that the DTA
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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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Russia suspends DTAs with 38 unfriendly countries
The Russian Ministry of Foreign Affairs has declared to suspend application of double tax agreements (DTAs) with unfriendly 38 countries that have introduced unilateral economic restrictions against Russia. The potential repercussions entail
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Tax Treaty Brief: May 2023
Hong Kong and Mauritius On 26 April 2023, the Chief Executive in Council of Hong Kong issued an Order to implement the provisions of the Double Taxation Agreement (DTA) with Mauritius. Czech Republic and Kosovo On 20 April 2023, the
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