OECD: Discussion draft on attribution of profits to permanent establishments
On 4 July 2016 the OECD published a discussion draft on additional guidance on the attribution of profits to permanent establishments, as part of the follow-up to the work on base erosion and profit shifting (BEPS). Comments are invited from
See MoreUK: Double tax agreement with Algeria enters into force
The double taxation agreement between the UK and Algeria entered into force on 26 June 2016. The agreement was signed on 18 February 2015. The agreement will be effective in the UK from 1 January 2017 for withholding tax; from 1 April 2017 for
See MoreIMF report comments on the economic position of Germany
On 24 June 2016 the IMF published a report and selected issues paper following the conclusion of consultations with Germany under Article IV of the IMF’s articles of agreement. Germany’s economy has continued its growth momentum with domestic
See MoreNamibia-increase of withholding tax rate of non-resident directors’ fees
In Namibia, the withholding tax rate applicable to directors’ fees paid to non-residents has become 25% with effect from 21 June 2016. Non-resident directors are no more obliged to include the directors. Fees in their income tax returns since the
See MoreUK publishes text of double tax agreement with the United Arab Emirates
On 28 June 2016 the UK published the text of the double taxation agreement with the United Arab Emirates (UAE) that was signed on 12 April 2016. The agreement generally follows the provisions of the OECD Model Tax Convention but the following points
See MoreUK publishes double taxation agreement with Turkmenistan
On 27 June 2016 the UK published the text of the double tax agreement with Turkmenistan. The agreement was signed on 10 June 2016 and has not yet entered into force. The following aspects of the treaty should be noted: Permanent establishment The
See MoreUK publishes text of double tax agreement with Uruguay
On 28 June 2016 the UK published the text of the double tax convention with Uruguay signed on 24 February 2016. The agreement is not yet in force. The provisions of the agreement generally follow the OECD Model but the following items are of
See MoreNigeria: Withholding tax rate for construction-related payments
The Finance Ministry has approved recommendations from IRS to withdraw and revoke a rate reduction for withholding tax under the companies’ income tax rules. The withholding tax regulations had effective on 1st January 2015 and from that time the
See MoreArgentina- Exempt income limit increased for withholding tax on domestic payments
In Argentina, General Resolution 3884(AFIP) was published in the Official Gazette of 26 May 2016 and became in force from that date. The new Resolution amends General Resolution 830 (AFIP) which establishes a widespread system of withholding tax on
See MoreDTA between Somalia and Turkey signed
An Income Tax Treaty between Somalia and Turkey has signed on 3rd June 2016 in
See MoreOECD releases request for input on multilateral instrument to implement tax treaty related BEPS measures
On 31 May 2016 the OECD released a request for input inviting comments from interested parties on the multilateral instrument to implement the tax treaty related measures in the OECD/G20 action plan on base erosion and profit shifting (BEPS). Input
See MoreGreece: Withholding tax on dividends and taxation of dividend income
The Public Revenue Authority has published Circular POL 1068 on 2nd June 2016 for providing clarifications on the increased 15% withholding tax rate and the taxation of dividend income earned. The Circular settles the provisions of Law 4389/2016
See MoreSingapore and Cambodia sign Income Tax Treaty
Singapore and Cambodia have entered into a double taxation avoidance agreement, on 20 May 2016, to boost cross-border trade and investment between the two countries The Agreement clarifies the taxing rights of both countries on all forms of income
See MoreUK: Consultation on changes to double tax treaty passport scheme
The UK imposes withholding tax of 20% on interest paid to overseas lenders. This rate is reduced under some double tax treaties and in this case HMRC can issue a notice directing the UK borrower to apply the reduced rate of withholding tax to
See MoreDTA between UAE and Uruguay ratified
The Income and capital Tax Treaty (2014) between United Arab Emirates and Uruguay has been ratified by Uruguay according to the Law No. 19.393 on 20th May
See MoreTreaty between Botswana and Czech Republic negotiated
The second round of negotiations for a tax treaty between Botswana and the Czech Republic is arranged to take place in Prague from 18th to 21st April
See MoreDTA between Morocco and Slovenia signed
An Income Tax Treaty (2016) between Morocco and Slovenia was signed on 5th April 2016 in
See MoreDTA between Chile and Uruguay signed
An Income and Capital Tax Treaty (DTA) between Chile and Uruguay has been signed on 1st April 2016 in
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