Peru 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
See MoreUN releases the 2017 update to the UN Model Convention
The UN released the 2017 update to the UN Model Convention at the 16th Session of the UN Committee of Experts in New York held from 14 to 17 May 2018. The updated Convention contains a new preamble emphasizing that tax treaties should not create
See MoreQatar: Qatari Amir approves a decree to ratify existing DTA with Gambia
The Amir of Qatar, Sheikh Tamim bin Hamad Al Thani, has approved a decree on May 13, 2018, for the ratification of the existing income tax treaty with Gambia for the avoidance of double taxation. This treaty was signed on November 18, 2014 and it
See MoreHong Kong and India sign an agreement on avoidance of double taxation
On 19 March 2018, Hong Kong and India signed a tax treaty for the avoidance of double taxation. The agreement sets out the allocation of taxing rights between the two jurisdictions and will help investors better assess their potential tax
See MoreLuxembourg and France sign new tax treaty
On 20 March 2018, Luxembourg and France signed a new income tax treaty and a new protocol, replacing the current double tax treaty signed on 1 April 1958. The Treaty contains a number of treaty-based recommendations including BEPS action 14 (making
See MoreOECD announces date of entry into force of multilateral instrument
On 22 March 2018 the OECD announced that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting is to enter into force on 1 July 2018. The Convention allows the signatories to quickly and
See MoreNetherlands-Malawi: Dutch Lower House of Parliament approves tax treaty
The Dutch lower house of parliament approved the pending income tax treaty with Malawi on 15th March 2018, signed on 19th April 2015. The treaty enters into force on the last day of the month following the month in which the ratification instruments
See MoreMorocco: Council of Ministers approve DTA with Zambia
On January 22, 2018, the Council of Ministers of Morocco has approved the income tax treaty with Zambia. The treaty provides for the avoidance of double taxation and the allocation of taxing rights over various categories of income. It was signed on
See MoreIsrael: DTA with Austria will enter into force on March 1, 2018
On March 1, 2018, the Double Taxation Agreement (DTA) between Austria and Israel will enter into force .This will be applicable from January 1, 2019. From this date, the new DTA replaces the existing DTA of
See MoreCroatia: Parliament ratifies DTA with Kazakhstan
The parliament ratified the Double Taxation Agreement (DTA) on January 26, 2018, with Kazakhstan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. It was signed on October 12,
See MoreKazakhstan: Senate approves protocol to DTA with India
On January 25, 2018, the upper chamber of the parliament or the Senate of Kazakhstan approved the amending protocol of Double Taxation Agreement (DTA) with India. It was approved by the lower chamber of parliament on December 20,
See MoreBahrain: Cabinet approves tax treaty with Egypt
The Bahrain Cabinet has approved the law for the ratification of the new income tax treaty on 22th January 2018, with Egypt for the avoidance of double taxation. The treaty was signed 26 April 2016, will enter into force after the ratification
See MoreCzech Republic: DTA signs with Korea (Rep.)
A treaty was signed on January 12, 2018, between Czech Republic and Korea (Rep.) for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion. It will replace the existing double tax agreement after being
See MoreUAE: Cabinet approves DTA with Croatia
The Cabinet of United Arab Emirates has approved the income tax agreement on January 7, 2018, with Croatia for the avoidance of double taxation and the prevention of fiscal
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