UK: Double tax treaty with Isle of Man enters into force
The double tax treaty between the UK and the Isle of Man entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and the Isle of Man for the avoidance of double taxation which ceases to have effect from the
See MoreUK: Double tax treaty with Jersey enters into force
The double tax treaty between the UK and Jersey entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and Jersey for the avoidance of double taxation which ceases to have effect from the dates on which the
See MoreDTA between India and Hong Kong enters into force
On 30 November 2018, the tax treaty between India and Hong Kong entered into force and the treaty will be effective from 1 April 2019. The tax treaty provides for a low withholding tax rate of 5% for dividend payments. Interest, royalties, and fees
See MoreOECD: Guidance on synthesised texts clarifying the impact of the MLI
The OECD announced on 16 November 2018 that new guidance is available for the development of synthesised texts presenting a clear overview of the modifications by countries to their bilateral double tax treaties as a result of applying the
See MoreOECD: Taxpayer input invited on seventh batch of Dispute Resolution peer reviews
On 15 November 2018 the OECD issued a request for taxpayers to submit input in relation to the seventh round of stage 1 peer reviews under action 14 of the OECD/G20 action plan on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreIMF working paper examines effects of tax treaties with investment hubs
An IMF working paper was released on 24 October 2018 entitled The Cost and Benefits of Tax Treaties with Investment Hubs: Findings from Sub-Saharan Africa. (Working Paper 18/227). Double tax treaties can affect returns to foreign investment through
See MoreUK: Amendments to tax treaty with Serbia
The UK-Serbia bilateral tax treaty has been updated as a result of changes made under the OECD’s multilateral instrument (MLI) for inclusion into bilateral treaties of tax treaty related provisions from the recommendations on base erosion and
See MoreUK: Revisions to double tax agreement with Slovenia
The UK's bilateral double tax treaty with Slovenia has been updated as a result of changes made under the OECD’s multilateral instrument (MLI) for inclusion into bilateral treaties of tax treaty related provisions from the action plan on base
See MoreNorway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
See MorePeru 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
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