Angola introduces amnesty measures with foreign technical and management services contracts
On 28 December 2018, Angola published Law no. 18/19 with the General State Budget for 2019. The main procedures are summarized as follows: The Special Contribution on technical support and management service contracts were maintained in 2019. The
See MoreChile: IRS clarifies Taxation of Dividends and Interest
Recently, the Internal Revenue Service (IRS) issued two separate Rulings 59 and 2546 to clarify the taxation of dividends and interest by resident and nonresident taxpayer. The two rulings separately discussed in below: Taxation of dividends Ruling
See MoreUK: New protocol to double tax agreement with Israel
On 11 January 2019 the UK and Israel signed a protocol to update the double tax agreement between the two countries, incorporating tax treaty related recommendations of the OECD project on base erosion and profit shifting (BEPS). The protocol will
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 MoreUK: Double tax treaty with Isle of Man enters into force
The double tax treaty between the UK and the Isle of Man entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and the Isle of Man for the avoidance of double taxation which ceases to have effect from the
See MoreUK: Double tax treaty with Jersey enters into force
The double tax treaty between the UK and Jersey entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and Jersey for the avoidance of double taxation which ceases to have effect from the dates on which the
See MoreDTA between India and Hong Kong enters into force
On 30 November 2018, the tax treaty between India and Hong Kong entered into force and the treaty will be effective from 1 April 2019. The tax treaty provides for a low withholding tax rate of 5% for dividend payments. Interest, royalties, and fees
See MoreOECD: Guidance on synthesised texts clarifying the impact of the MLI
The OECD announced on 16 November 2018 that new guidance is available for the development of synthesised texts presenting a clear overview of the modifications by countries to their bilateral double tax treaties as a result of applying the
See MoreOECD: Taxpayer input invited on seventh batch of Dispute Resolution peer reviews
On 15 November 2018 the OECD issued a request for taxpayers to submit input in relation to the seventh round of stage 1 peer reviews under action 14 of the OECD/G20 action plan on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreIMF working paper examines effects of tax treaties with investment hubs
An IMF working paper was released on 24 October 2018 entitled The Cost and Benefits of Tax Treaties with Investment Hubs: Findings from Sub-Saharan Africa. (Working Paper 18/227). Double tax treaties can affect returns to foreign investment through
See MoreUK: Amendments to tax treaty with Serbia
The UK-Serbia bilateral tax treaty has been updated as a result of changes made under the OECD’s multilateral instrument (MLI) for inclusion into bilateral treaties of tax treaty related provisions from the recommendations on base erosion and
See MoreUK: Revisions to double tax agreement with Slovenia
The UK's bilateral double tax treaty with Slovenia has been updated as a result of changes made under the OECD’s multilateral instrument (MLI) for inclusion into bilateral treaties of tax treaty related provisions from the action plan on base
See MoreNorway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
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 MoreRussia: Central Bank hikes late payment interest penalty
On 14 September 2018, Russia’s central bank raised the late tax payment interest rate from 7.25% to 7.5% and said it would not make any foreign currency purchases until the end of the year, citing the risk of higher inflation and rouble
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 MorePlatform for Collaboration on Tax: taxation of offshore indirect transfers
On 16 July 2018 the Platform for Collaboration on Tax (PCT) published a new draft of its toolkit on the taxation of offshore indirect transfers of assets. The PCT was set up by the IMF, OECD, UN and World Bank at the request of the G20 of countries
See MoreUK: Provisions of updated tax treaty with Cyprus
The updated UK-Cyprus Double Taxation Agreement (DTA) signed on March 22 2018 aligns the provisions more closely with the OECD Model. Withholding tax The new treaty when in effect will provide for zero withholding tax on dividends unless they are
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