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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Tax Treaty Brief: April 2023
Denmark and France On 28 March 2023, Denmark ratified the new Double Taxation Agreement (DTA) with France, as published in the Danish official gazette. The DTA contains withholding tax rates for Dividends 0% for at least 10% capital holding;
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OECD: Peer Review Report on the Prevention of Treaty Shopping
On 21 March 2023 the OECD released the latest peer review results following assessment of the actions taken by each country to prevent tax treaty shopping under BEPS Action 6. The Fifth Peer Review Report on Treaty Shopping assesses the
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Tax Treaty Brief: March 2023
Andorra and Iceland On 28 February 2023, the Double Taxation Agreement (DTA) between Andorra and Iceland was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Egypt and
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Tax Treaty Brief: February 2023
Belarus and Zimbabwe On 31 January 2023, the Double Taxation Agreement (DTA) between Belarus and Zimbabwe was signed. The DTA contains withholding tax rates for Dividends 5% for at least 20% capital holding; otherwise, 15%, Interest 10%, and
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OECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
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Tax Treaty News: January 2023
Austria and United Arab Emirates On 1 March 2023, the amending protocol to the Double Taxation Agreement (DTA) between Austria and the United Arab Emirates (UAE) will enter into force. The protocol generally applies from 1 January
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Tax Treaty News: December 2022
Chile and Netherlands On 30 November 2022, the Double Taxation Agreement (DTA) between Chile and Netherlands entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 15%,
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Tax Treaty News: November 2022
Georgia and Poland On 27 October 2022, the Polish Senate approved the Double Taxation Agreement (DTA) with Georgia. Czech Republic and Qatar On 25 October 2022, the Double Taxation Agreement (DTA) between Czech Republic and Qatar
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Hong Kong and Mauritius enter into tax pact
On 7 November 2022, 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
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UN: Increasing Tax Transparency
At the meeting of the UN Committee of Experts on International Cooperation in Tax Matters from 18 to 21 October 2022 the Subcommittee on increasing tax transparency reported on its work program. The Subcommittee was formed to consider ways to
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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
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Tax Treaty News: October 2022
Georgia and Poland On 29 September 2022, the lower house of the Polish parliament approved the Double Taxation Agreement (DTA) with Georgia. Tanzania and UAE On 27 September 2022, the Double Taxation Agreement (DTA) between Tanzania and
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