OECD Releases Information and Statistics on Mutual Agreement Procedures
On 14 November 2023 the OECD released the 2022 Mutual Agreement Procedures (MAP) Statistics, covering 133 jurisdictions worldwide. The release of these statistics each year is part of the actions to improve dispute prevention and resolution in line
See More
UN Tax Committee considers transfer pricing and treaty issues
The 27th session of the UN Committee of Experts on International Cooperation in Tax Matters took place from 17 to 20 October 2023. Subcommittees dealing with various areas of taxation presented updates to the Tax Committee on their
See More
Tax Treaty Brief: October 2023
Andorra and Croatia On 28 September 2023, the Croatian parliament approved the ratification of the Double Taxation Agreement (DTA) with Andorra. Iran and Ukraine On 26 September 2023, Ukraine has published Letter No. 72/14-612/1-114650
See MoreTax Treaty Brief: September 2023
Bangladesh and Hong Kong On 30 August 2023, the Govt. officials from Bangladesh and Hong Kong signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
See More
Hong Kong and Bangladesh enter into tax pact
On 30 August 2023, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, on behalf of the Hong Kong Special Administrative Region Government signed a comprehensive avoidance of double taxation agreement (CDTA) with Bangladesh.
See MoreTax Treaty Brief: August 2023
Albania and Slovak Republic On 26 July 2023, the Council of Ministers in Albania approved the draft legislation for the ratification of the Double Taxation Agreement (DTA) with the Slovak Republic. Germany and Switzerland On 26 July
See More
OECD: Facilitating the Use of Treaty Exchanged Information for Non-Tax Purposes
Sharing of treaty-exchanged information with relevant law enforcement agencies for non-tax purposes helps to combat illicit financial flows (IFFs), money laundering and corruption. Institutions often face operational challenges in implementing this
See MoreTax Treaty Brief: July 2023
Cyprus and Netherlands On 30 June 2023, the Double Taxation Agreement (DTA) between Cyprus and the Netherlands entered into force. The DTA contains withholding tax rates for Dividends 0% for at least 5% capital holding; otherwise, 15%,
See MoreTax Treaty Brief: June 2023
Slovenia and Switzerland On 30 May 2023, Slovenia and Switzerland officially signed an amending protocol to update the Double Taxation Agreement (DTA) between the two nations. The primary objective of this protocol is to ensure that the DTA
See More
UK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
See More
Russia suspends DTAs with 38 unfriendly countries
The Russian Ministry of Foreign Affairs has declared to suspend application of double tax agreements (DTAs) with unfriendly 38 countries that have introduced unilateral economic restrictions against Russia. The potential repercussions entail
See MoreTax Treaty Brief: May 2023
Hong Kong and Mauritius On 26 April 2023, the Chief Executive in Council of Hong Kong issued an Order to implement the provisions of the Double Taxation Agreement (DTA) with Mauritius. Czech Republic and Kosovo On 20 April 2023, the
See MoreTax Treaty Brief: April 2023
Denmark and France On 28 March 2023, Denmark ratified the new Double Taxation Agreement (DTA) with France, as published in the Danish official gazette. The DTA contains withholding tax rates for Dividends 0% for at least 10% capital holding;
See MoreOECD: Peer Review Report on the Prevention of Treaty Shopping
On 21 March 2023 the OECD released the latest peer review results following assessment of the actions taken by each country to prevent tax treaty shopping under BEPS Action 6. The Fifth Peer Review Report on Treaty Shopping assesses the
See MoreTax Treaty Brief: March 2023
Andorra and Iceland On 28 February 2023, the Double Taxation Agreement (DTA) between Andorra and Iceland was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Egypt and
See MoreTax Treaty Brief: February 2023
Belarus and Zimbabwe On 31 January 2023, the Double Taxation Agreement (DTA) between Belarus and Zimbabwe was signed. The DTA contains withholding tax rates for Dividends 5% for at least 20% capital holding; otherwise, 15%, Interest 10%, and
See MoreOECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
See MoreTax Treaty News: January 2023
Austria and United Arab Emirates On 1 March 2023, the amending protocol to the Double Taxation Agreement (DTA) between Austria and the United Arab Emirates (UAE) will enter into force. The protocol generally applies from 1 January
See More