Canada 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
See MoreUN: Tax Committee Discusses Interaction of Investment Agreements and Tax
In its meetings from 19 to 28 October 2021 the UN Committee has covered, among other issues, the interaction of tax, trade and investment agreements. A Note on the Interaction of Tax Trade and Investment Agreements was prepared by the UNDESA
See MoreTurkey extends dates for reduced withholding to interest on TRY deposit accounts
On 30 September 2021, the Turkish Revenue Administration has issued Presidential Decision No. 4561 in the Official Gazette extending the dates for reduced withholding rates on interest on deposit accounts entitled in Turkish lira (TRY). The reduced
See MoreFrance: Government presents 2022 Finance Bill to National Assembly
On 22 September 2021, the Minister of Economy, Finance and Recovery, Bruno Le Maire and the Minister Delegate in charge of Public Accounts, Olivier Dussopt, presented 2022 Finance Bill to the National Assembly. Some of the proposed changes of this
See MoreOECD: Measures to Facilitate Withholding Tax Relief Claims
On 6 September 2021 the OECD issued a document entitled: Tax administration responses to COVID-19: Administrative measures to facilitate withholding tax relief claims. Cross-border withholding tax relief procedures are frequently reliant on
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreArgentina: AFIP publishes a Resolution on dividend WHT rate
On 26 August 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 5060/2021 to update previous General Resolution 4478/2019. The new Resolution is about the application of the dividend withholding tax and the
See MoreTurkey sets 0% withholding tax rate on certain Financial Instruments income
On 4 September 2021, Turkey has published Presidential Decision No. 4454 in the Official Gazette, which sets 0% (reduced from 10%) withholding tax rate on certain venture capital and real estate investment fund earnings. The reduced withholding
See MoreTurkey extends temporarily reduced withholding rates
On 30 July 2021, Turkey's Revenue Administration has published Presidential Decision No. 4311 in the Official Gazette extending the temporarily reduced withholding rates for deposit interests and dividends paid in return for participation accounts,
See MoreOECD: Stage two peer review report on Chile’s compliance with BEPS action 14
On 26 July 2021 the OECD published the stage two peer review report on Chile’s compliance with the minimum standard under action 14 of the action plan on base erosion and profit shifting (BEPS). BEPS Action 14 is concerned with making dispute
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