Poland, UAE sign exchange of notes to income tax treaty
Poland and the UAE signed an exchange of notes on their 1995 tax treaty on 24 February 2025 and 18 April 2025. The exchange notes confirm that the Abu Dhabi Developmental Holding Company qualifies as a governmental institution, making it eligible
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Czech Republic: Supreme Court rules on royalty beneficial ownership
The Czech Republic’s Supreme Administrative Court issued a ruling on the concept of beneficial ownership concerning royalty payments. The case centred around Avon Cosmetics Limited, a UK company based in Northampton, which granted sublicenses
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Hong Kong and Mauritius enter into tax pact
On 7 November 2022, 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
See MoreSouth Africa: SARS publishes the comprehensive guide to dividends tax
On 12 May 2022, the South African Revenue Service (SARS) published the 5th issue of the Comprehensive Guide to Dividends Tax. The purpose of this guide is to assist users in gaining a more in-depth understanding of dividends tax. The foundation
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 MoreTurkey sets 0% withholding tax rate on certain TRY deposit accounts
On 31 December 2021, Turkey has published Presidential Decision No. 5046 in Official Gazette. Accordingly, Turkey has set 0% withholding tax will be applicable on income from certain TRY deposit accounts and participation accounts. As of 28
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MoreTurkey extends dates for reduced withholding to interest on TRY deposit accounts
On 30 September 2021, the Turkish Revenue Administration has issued Presidential Decision No. 4561 in the Official Gazette extending the dates for reduced withholding rates on interest on deposit accounts entitled in Turkish lira (TRY). The reduced
See MoreFrance: Government presents 2022 Finance Bill to National Assembly
On 22 September 2021, the Minister of Economy, Finance and Recovery, Bruno Le Maire and the Minister Delegate in charge of Public Accounts, Olivier Dussopt, presented 2022 Finance Bill to the National Assembly. Some of the proposed changes of this
See MoreMexico: Executive Branch submits 2022 economic proposal to Congress
On 8 September 2021, the Mexican Executive Branch has submitted Economic Package for the fiscal year 2022 including a proposal of Tax Reform. The proposed 2022 Tax Law clarifies income tax law, value-added tax (VAT) law, excise tax (duty)
See MoreArgentina: AFIP publishes a Resolution on dividend WHT rate
On 26 August 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 5060/2021 to update previous General Resolution 4478/2019. The new Resolution is about the application of the dividend withholding tax and the
See MoreTurkey sets 0% withholding tax rate on certain Financial Instruments income
On 4 September 2021, Turkey has published Presidential Decision No. 4454 in the Official Gazette, which sets 0% (reduced from 10%) withholding tax rate on certain venture capital and real estate investment fund earnings. The reduced withholding
See MoreTurkey extends temporarily reduced withholding rates
On 30 July 2021, Turkey's Revenue Administration has published Presidential Decision No. 4311 in the Official Gazette extending the temporarily reduced withholding rates for deposit interests and dividends paid in return for participation accounts,
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 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 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
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