UK: New protocol to double tax agreement with Israel
On 11 January 2019 the UK and Israel signed a protocol to update the double tax agreement between the two countries, incorporating tax treaty related recommendations of the OECD project on base erosion and profit shifting (BEPS). The protocol will
See MoreUK: 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 MoreGermany: Issues new procedure for non-residents regarding reimbursement of the withholding tax
Recently, the tax administration published an updated guidance on the tax refund procedure for non-residents to claim a 15% refund of withholding tax on portfolio dividends. According to the new procedure, as from 1 January 2017, the income from
See MoreIndia: Higher tax rate not applied when tax is withheld under tax treaty
The Ahmedabad Bench of the Income-tax Appellate Tribunal in the case of: Uniphos Environtronic (P.) Ltd. v. DCIT 79, held that where the tax has been deducted on the basis of the beneficial provisions of the tax treaties, the provisions of
See MoreDouble tax treaty between Hungary and Iran enters into force
The double tax treaty between Hungary and Iran came into force on 1 January 2017. The treaty defines the term "resident" as a person that under the laws of either country is liable to tax there by reason of domicile, residence, place of
See MoreIndia and Cyprus Income tax treaty renegotiated
The Income Tax Treaty between Cyprus and India signed on 18 November 2016, have become available the treaty’s details. Both countries generally provide for the credit method to avoid double taxation. This treaty gives the following withholding tax
See MoreGuidance from Japan’s tax agency relating to tax agreement with Taiwan
Japan’s national tax agency on 30 November 2016 released guidance with respect to withholding taxes and forms for application of the mutual exemption provisions for income of foreign residents. The Guidance on an amendment to withholding taxes
See MoreUK: Double tax treaty with Senegal effective in UK
The double taxation agreement between the UK and Senegal that was signed on 26 February 2015 entered into force on 30 March 2016. In the UK the agreement is effective from any year of assessment beginning on or after 6 April 2016 for income tax or
See MoreUK: Double tax agreement with Algeria enters into force
The double taxation agreement between the UK and Algeria entered into force on 26 June 2016. The agreement was signed on 18 February 2015. The agreement will be effective in the UK from 1 January 2017 for withholding tax; from 1 April 2017 for
See MoreUK: Consultation on changes to double tax treaty passport scheme
The UK imposes withholding tax of 20% on interest paid to overseas lenders. This rate is reduced under some double tax treaties and in this case HMRC can issue a notice directing the UK borrower to apply the reduced rate of withholding tax to
See MoreFrance and Singapore Sign Bilateral Double Tax Agreement
A revised double tax treaty was signed between Singapore and France on 15 January 2015. In the case of the Singapore, the treaty covers the income tax. In the case of France, the treaty covers the income tax, corporation tax, contributions on
See MoreMalta – Russia DTA
On May 22 2014 the double taxation agreement (DTA) between Malta and Russia is to enter into force. Under the agreement, withholding tax on dividends paid from Russia is restricted to 5% where the recipient company has a 25% shareholding in the
See MoreRuling on Taxes within DTAs Provided in South Africa
The Legal and Policy Division of the South African Revenue Service (SARS) has issued a Binding General Ruling (BGR) on income taxes, or substantially similar taxes, following the double tax agreements (DTAs) of South Africa. According to this BGR
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