Chile clarifies tax rules for technical services under Chile-Colombia tax treaty
Chile’s tax authority (SII) issued Letter Ruling No. 711 on 10 April 2025 regarding the taxation of payments for technical services under the 2007 Chile-Colombia tax treaty. The letter addresses two Colombians providing remote software
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UN: New Article 12AA on Taxation of Services Presented for Approval
The 30th session of the UN Committee of Experts on International Cooperation in Tax Matters is being held from 24 to 27 March 2025. On 25 March 2025 the Subcommittee on Taxation Issues Related to the Digitalized and Globalized Economy presented
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Kenya: High Court rules no withholding tax on service fees in Kenya-France treaty
Kenya’s High Court delivered its ruling regarding the case – Income Tax Appeal E044 of 2021 – Commissioner of Domestic Taxes v Total Kenya Limited. Total Kenya Limited (TKL) is a fully owned subsidiary of French company, Total Outre Mer (TOM).
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UN: Tax Committee Discusses a New Combined Treaty Article on Services
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 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 MoreUN: Launch of the updated Model Tax Convention
On 26 April 2022 the launch of the 2021 update of the UN Model Tax Convention took place as part of the UN’s “Financing for Development” forum. There were presentations and a panel discussion. New Articles 12A and 12B The new Article
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreOECD: Measures to Facilitate Withholding Tax Relief Claims
On 6 September 2021 the OECD issued a document entitled: Tax administration responses to COVID-19: Administrative measures to facilitate withholding tax relief claims. Cross-border withholding tax relief procedures are frequently reliant on
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: 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 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 MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreUN: Draft Model Treaty Provision on Digital Services
On 6 August 2020 the United Nations (UN) published draft Article 12B for the UN Model Double Taxation Convention, to provide for the allocation of taxable income from automated digital services. The draft Article states that income from
See MoreECJ: Ruling on Outbound Dividends and Free Movement of Capital
On 9 March 2020 a ruling by the European Court of Justice (ECJ) in a case on free movement of capital was published. The case State of Canada v Autoridade Tributaria e Aduaneira related to dividends paid to the Canada Pension Plan Investment Board
See MoreOECD: Guidance and IT Tools released to support the TRACE system
On 25 February 2020 the OECD issued guidance on the the technical implementation of the TRACE initiative (Treaty Relief and Compliance Enhancement), together with the relevant IT formats. The TRACE system permits claims to be made in relation to
See MoreSingapore signs DTA with Turkmenistan
On 27 August 2019, Singapore signed a Double Tax Treaty (DTA) with Turkmenistan. The DTA will enhance the cross-border trade and investment between both countries. It lowers the withholding tax rates on income flows arising from cross-border
See MoreUK: Double tax treaty with Lesotho takes effect
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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