Poland: MOF announces tax measures to attract foreign investment
On 14 June 2021, the Polish Ministry of Finance announced a new package of measures to encourage foreign investment in Poland. Accordingly, 95% tax exemption for dividends received by Polish holding companies after a one-year holding period,
See MoreOECD: Conference of the Parties to the MLI approves an opinion on interpretation and implementation
On 3 May 2021 an opinion of interpretation and implementation was reached by a conference of the parties to the multilateral instrument (MLI) for inclusion in bilateral tax treaties of the tax treaty related provisions arising from the action plan
See MoreUN amends commentary to model tax treaty on taxation of software payments
At the 22nd session of the UN Committee of Experts on International Cooperation in Tax Matters, held virtually between 19 and 28 April 2021, a decision was made to revise the commentary to Article 12 (royalties) of the UN Model Tax Treaty in
See MoreUN: Third edition of the Practical Manual on Transfer Pricing for Developing Countries
Following approval at the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters, held from 19 to 28 April 2021, the UN has published the third edition of its Practical Manual on Transfer Pricing for
See MoreColombia: Government submits Tax Reform Bill to Congress
On 15 April 2021, the Colombian government has submitted new Tax Reform Bill (Sustainable Solidarity Act) to Congress. The Bill modifies corporate income tax (CIT), value-added tax (VAT) and personal income tax. The main tax measures of the Tax
See MoreUN: Meeting of Committee of Tax Experts
On 19 to 28 April 2021 the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters will be held in a series of virtual meetings. UN Model Treaty – Revised Royalty definition The Committee will
See MoreIMF and World Bank: Discussion of Digital Services Tax
On 13 April 2021 the IMF and World Bank tax conference on Minimum and Digital Taxation: Consensus or Divide discussed aspects of unilateral digital service taxes. The discussions covered the scope of the taxes, tax treaty issues and challenges for
See MoreOECD: 2020 Peer Review Report on Treaty Shopping
On 1 April 2021 the OECD released the latest annual peer review report on adoption of measures against treaty shopping. The report on Action 6 of the OECD project on base erosion and profit shifting (BEPS) noted that abuse of double tax
See MoreOECD: Profiles for Countries Applying Arbitration under the MLI
On 23 March 2021 the OECD published Arbitration Profiles for 30 jurisdictions that are applying the arbitration provisions in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MorePlatform for Collaboration on Tax: Toolkit on Tax Treaty Negotiations
The Platform for Collaboration on Tax (PCT) was set up by the IMF, OECD, UN and World Bank Group. The PCT has been developing a series of toolkits to guide developing countries in the implementing policy options. The PCT's Toolkit on Tax Treaty
See MoreCosta Rica: Legislative Assembly approves a bill to increase WHT rates
The Costa Rican Legislative Assembly has approved a bill considering to increase withholding tax rates on various types of income paid to non-residents by 5%. The bill provides the 20% withholding tax rates for dividends and interest, 30% for
See MoreJapan and Georgia enter into tax pact
On 29 January 2021, “Convention between Japan and Georgia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (hereinafter referred to as the New Convention) was signed in
See MoreOECD: Updated guidance on tax treaties and the impact of the pandemic
On 21 January 2021 the OECD published on its website updated guidance on tax treaties and the impact of the pandemic. The guidance sets out the views of the OECD Secretariat on the interpretation of tax treaty provisions, reflecting the general
See MoreNew judgement of the Russian court on beneficial ownership
Roustam VakhitovInternational Tax PartnerCrowe Expertiza+3 164 082 [email protected] On 14 December 2020 the Moscow State Arbitration Court released its judgement on case involving Dutch and Russian companies of Kinross group,
See MoreCroatia: Government publishes Tax Reform Law 2021
On 11 December 2020, the Government published Tax Reform Law for the year 2021, which includes Law on Amendments to the Income Tax Law, the Law on Amendments to the Corporate Tax Law, and the Law on Amendments to the Value Added Tax Law. The Tax
See MoreRussia’s possible termination of DTT with the Netherlands
Roustam VakhitovInternational Tax PartnerCrowe Expertiza+3 164 082 [email protected] On 4 December 2020 the Russian Ministry of Finance announced initiation of the termination of DTT with the Netherlands due to absence of process
See MoreGerman Upper House Approves MLI to Implement Tax Treaty Related BEPS Measures
On 6 November 2020 the Bundesrat (the upper house in the German parliament) gave its approval to ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the
See MoreTurkey: Parliament passes Law on certain tax amendments for 2021
On 11 November 2020, the Turkish Parliament approved Law No. 7256 on “Restructuring Public Receivables and Amending Certain Laws”, which was published on 17 November 2020 in the Official Gazette. With the aforementioned Law, finalized public
See More