UN: Tax Committee discusses UN Model Commentary Issues – PE, treatment of software, CIVs
A report by James R. Border, Law Office of James R Border P.A., Fort Lauderdale, Florida On 22 October 2020 the United Nations Committee of Experts on International Tax Matters addressed several items relating to the UN Model Tax Convention.
See MoreNigeria: President presents National Budget for 2021
On 8 October 2020, the President, Muhammadu Buhari, presented the National Budget for the year 2021 to a joint session of the National Assembly consisting of the Senate and the House of Representatives. The 2021 Budget is titled 'Economic Recovery
See MoreHong Kong and Georgia enter into tax pact
On 5 October 2020, 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
See MoreDenmark: Tax Minister announces to exempt nonresident charitable organizations from WHT
On 14 September 2020, the Tax Minister announced that Government has a plan to release a Bill in December 2020 regarding the exemption of on non-resident charitable organizations from Danish withholding tax (WHT) on portfolio dividends. At present,
See MoreMexico: Executive Branch submits 2021 economic proposal to Congress
On 8 September 2020, the Mexican Executive Branch has submitted Economic Package for fiscal year 2021 including a proposal of Tax Reform. The proposed 2021 Tax Law clarifies income tax law, value-added tax (VAT) law, and federal tax code. Tax key
See MoreHong Kong and Serbia enter into tax pact
On 28 August, 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 Serbia. The
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreUN: Draft Model Treaty Provision on Digital Services
On 6 August 2020 the United Nations (UN) published draft Article 12B for the UN Model Double Taxation Convention, to provide for the allocation of taxable income from automated digital services. The draft Article states that income from
See MoreCOVID 19: Poland further postpones withholding tax rules to 31 December 2020
On 24 June 2020, the Polish Ministry of Finance released a decree that further postponed the effective date of withholding tax rules for corporate income tax purposes. The new effective date is 31 December 2020. The withholding tax was originally
See MorePlatform for Collaboration on Tax: Draft Toolkit on Tax Treaty Negotiations
The Platform for Collaboration on Tax (PCT) has issued a draft toolkit on tax treaty negotiations. The period for feedback from interested parties is 29 June 2020 to 10 September 2020. The PCT was set up by the OECD, IMF, World Bank and UN to
See MoreOECD: Platform for Collaboration on Tax Finalises Toolkit on Offshore Indirect Transfers
On 4 June 2020 the Platform for Collaboration on Tax issued a final version of the Toolkit on the Taxation of Offshore Indirect Transfers. The Toolkit provides guidance in relation to designing measures to enable a country to tax gains arising
See MoreEgypt: Tax measures in response to COVID-19 pandemic
Recently, the Egyptian Government has announced several tax measures to mitigate the financial effect in response to the COVID-19 pandemic. The main tax measures are as following: Capital Gains: the extension of the suspension from the taxation
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 MoreOECD releases second peer review report on prevention of treaty abuse
On 24 March 2020 the OECD published the second peer review report on the implementation by countries of the minimum standard under Action 6 of the action plan on base erosion and profit shifting (BEPS). This is the second peer review report under
See MoreOECD: Tax issues for cross border workers during the COVID-19 crisis
On 7 April 2020 the OECD published on its website guidance on tax issues relating to cross-border workers during the crisis. As a result of travel restrictions and quarantine requirements many cross-border workers cannot go to the country where
See MoreEcuador: Internal Revenue publishes rules on dividend withholding tax
On 20 February 2020, the Internal Revenue Service published a Resolution NAC-DGERCGC20-00000013 of 20 February 2020 regarding rules of how to distribute the dividend withholding tax (WHT) by a resident company or a permanent establishment in
See MoreSouth Africa: SARS issues draft interpretation notes regarding WHT on interest and royalties
On 18 March 2020, the South African Revenue Service (SARS) issued two draft interpretation notes regarding the withholding tax (WHT) on interest and royalties for public comments until 29 May 2020. The draft interpretation note on withholding
See MoreECJ: Ruling on Outbound Dividends and Free Movement of Capital
On 9 March 2020 a ruling by the European Court of Justice (ECJ) in a case on free movement of capital was published. The case State of Canada v Autoridade Tributaria e Aduaneira related to dividends paid to the Canada Pension Plan Investment Board
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