Austria: MOF Updates Guidance on COVID-19 treaty Issues
On 20 June 2022, the Ministry of Finance published a Circular (no. 2022-0.433.029 of 17 June 2022) clarifying various tax treaty issues that have arisen due to the COVID-19 pandemic, including permanent establishments(PE) and the application of the
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Brazil and China On 23 May 2022, an amending protocol to the Double Taxation Agreement (DTA) between Brazil and China was signed to update the agreement. Russia and Ukraine On 22 May 2022, the Ukrainian parliament approved the bill
See MoreSouth Africa: SARS publishes the comprehensive guide to dividends tax
On 12 May 2022, the South African Revenue Service (SARS) published the 5th issue of the Comprehensive Guide to Dividends Tax. The purpose of this guide is to assist users in gaining a more in-depth understanding of dividends tax. The foundation
See MoreTax Treaty News: May 2022
Netherlands and Poland On 30 April 2022, the amending protocol to the Double Taxation Agreement (DTA) between Netherlands and Poland was entered into force. The protocol will apply from 1 January 2023. Iraq and Turkey On 26 April
See MoreUN: Launch of the updated Model Tax Convention
On 26 April 2022 the launch of the 2021 update of the UN Model Tax Convention took place as part of the UN’s “Financing for Development” forum. There were presentations and a panel discussion. New Articles 12A and 12B The new Article
See MoreTax Treaty News: April 2022
Chile and US On 29 March 2022, the United States (US) Senate approved the Double Taxation Agreement (DTA) with Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Guyana
See MoreOECD: Fourth Peer Review Report on Prevention of Tax Treaty Abuse
On 21 March 2022 the OECD released the fourth peer review report on tax treaty abuse under Action 6 of the action plan on base erosion and profit shifting (BEPS). The report looks at the measures that member countries of the OECD’s
See MoreTax Treaty News: March 2022
Cambodia and Turkey On 27 February 2022, the Double Taxation Agreement (DTA) between Cambodia and Turkey was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Israel and
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Sri Lanka and Turkey On 28 January 2022, the Double Taxation Agreement (DTA) between Sri Lanka and Turkey was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Argentina
See MoreTax Treaty News: January 2022
Sweden and UK On 31 December 2021, the amending protocol to the Double Taxation Agreement (DTA) between Sweden and the United Kingdom (UK) entered into force. The protocol applies from 1 January 2022. Kosovo and Netherlands On 31
See MoreTurkey sets 0% withholding tax rate on certain TRY deposit accounts
On 31 December 2021, Turkey has published Presidential Decision No. 5046 in Official Gazette. Accordingly, Turkey has set 0% withholding tax will be applicable on income from certain TRY deposit accounts and participation accounts. As of 28
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 Canada–Lithuania 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 Canada–Latvia Income Tax Convention with respect to certain royalties. Effective January 1, 2018, the
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreDominican Republic: DGII describes a guide regarding FTC
The Tax Authority has recently made a clarification through a Public Ruling, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. According to the letters, the maximum foreign income tax credit paid to a foreign
See MoreOECD: Building Effective Beneficial Ownership Frameworks
In November 2021 the Global Forum on Transparency and Exchange of Information for Tax Purposes, in collaboration with the Inter-American Development Bank (IDB), published a toolkit on Building Effective Beneficial Ownership
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreJapan signs exchange of notes on arbitration with Denmark
On 5 November 2021, the Japanese Ministry of Finance announced an exchange of notes with Denmark regarding the entry into force of the arbitration provisions in the 2017 income tax treaty between the two countries. Due to the exchange of notes, the
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