Tax 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
See MoreTax Treaty News: February 2022
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 MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreOECD: Stage Two Peer Review Report on Jersey under BEPS Action 14
On 24 January 2022 the OECD’s Inclusive Framework published the stage 2 peer review report on Jersey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreOECD: Stage Two Peer Review Report on Serbia under BEPS Action 14
On 24 January 2022 the OECD’s Inclusive Framework released the stage 2 peer review report on Serbia’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). The minimum standard under
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
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MoreUK Budget announcements for 2022/23
The latest UK budget announcements were made on 27 October 2021 including the following measures: Consultation on corporate re-domiciliation This consultation seeks views on the introduction of a UK re-domiciliation regime, which would make
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