UN: Tax Committee Discusses a New Combined Treaty Article on Services

March 21, 2024

The 28th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 19 to 22 March 2024. The digital economy subcommittee in its workstream B has been considering the function and relevance of physical

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UN: Guide on Tax Treaties for Investment Policymakers

February 15, 2024

On 13 February 2024 UNCTAD released a guide with the title Double taxation treaties: What investment policymakers need to know. The guide deals with the aspects of double tax treaties that are important for investment policymakers to understand, and

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OECD: Comments Received on Changes to the Commentary to Article 5

January 25, 2024

On 22 January 2024, the OECD published comments on proposed amendments to the commentary to Article 5 in relation to an alternative provision on activities in connection with the exploration and exploitation of natural resources. The additional

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UN Tax Committee considers transfer pricing and treaty issues

October 27, 2023

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

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UK: Consultation on Changes to Transfer Pricing Rules

June 21, 2023

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

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OECD: Updated guidance on tax treaties and the impact of the pandemic

January 22, 2021

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

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UN: Tax Committee discusses UN Model Commentary Issues – PE, treatment of software, CIVs

October 23, 2020

A report by James R. Border, Law Office of James R Border P.A., Fort Lauderdale, Florida On 22 October 2020 the United Nations Committee of Experts on International Tax Matters addressed several items relating to the UN Model Tax Convention.

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Ukraine submits draft law on amendments to the Tax Code to Parliament

September 26, 2019

On 30 August 2019, the Ukraine has submitted draft law no. 1210 to the Parliament amending the Tax Code on improving tax administration, removing technical and logical mismatches in the tax legislation. The three main areas of the draft law

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India: CBDT invites public comments on proposal to amend rules for profit attribution to PE

May 06, 2019

On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and

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UK: Double tax treaty with Lesotho takes effect

March 08, 2019

The double tax treaty between the UK and Lesotho takes effect in relation to UK corporation tax for financial years beginning on or after 1 April 2019. The treaty was signed on 3 November 2016 and entered into force on 18 September 2018. Permanent

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UN releases the 2017 update to the UN Model Convention

May 18, 2018

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

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OECD: 2017 edition of the Model Tax Convention released

December 19, 2017

On 18 December 2017 the OECD released the 2017 edition of the Model Tax Convention. This edition incorporates measures outlined in the final reports from the action plan on base erosion and profit shifting. The new edition reflects work on BEPS

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OECD: discussion draft sets out additional guidance on attribution of profits to PEs

June 27, 2017

On 22 June 2017 the OECD issued a new discussion draft with guidance on attribution of profits to permanent establishments (PEs), to replace the previous draft published in July 2016. The new discussion draft outlines the general principles for the

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UK: Details of double tax agreement with Colombia

November 07, 2016

Details are available of the double tax agreement between the UK and Colombia signed on 2 November 2016. The treaty generally conforms to the provisions of the OECD Model Tax Convention but the following should be noted: Permanent establishment A

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UK: Double tax agreement with Lesotho

November 06, 2016

The UK signed a double tax agreement with Lesotho on 3 November 2016. When it goes into effect it will replace the current agreement signed in 1997. The agreement generally follows the provisions of the OECD Model Tax Convention but the following

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OECD: Discussion draft on attribution of profits to permanent establishments

July 06, 2016

On 4 July 2016 the OECD published a discussion draft on additional guidance on the attribution of profits to permanent establishments, as part of the follow-up to the work on base erosion and profit shifting (BEPS). Comments are invited from

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Finland: Tax authority signs a co-operation pact with the African Tax Administration Forum (ATAF)

April 20, 2015

A co-operation pact was signed between Finnish tax authority and African Tax Administration Forum (ATAF) on 2 April, 2015. The aim of the co-operation pact is to support African tax authorities in implementing changes to their international tax

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Nigeria: Nonresident companies must file income tax return on real profits basis

February 13, 2015

The Federal Inland Revenue Services (FIRS) in Nigeria has issued a notice demanding all nonresident companies with a permanent establishment (PE) or fixed base (FB) to file tax returns on real basis. The new directive will be applicable to tax

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