Income tax treaty between Luxembourg and Laos
An income and capital tax treaty between Luxembourg and Laos has been ratified, and awaiting the exchange of instruments of ratification before the treaty can enter into force. The Luxembourg and Laos income tax treaty provides withholding tax rates
See MoreIn the Case of ADIT vs. Clifford Chance, the Tribunal ruled that professional services fees would be taxable in India
On 13 May 2013, the Special Bench of the Income Tax Appellate Tribunal issued its judgment in the case of ADIT vs. Clifford Chance. The Tribunal ruled that professional services fees would be taxable to the extent of the services actually
See MoreCanada: Quarterly formal interest rate due to include deemed interest income
The Revenue Agency (CRA) of Canada ensured that the quarterly prescribed interest rate used to determine the deemed interest income inclusion from a "pertinent loan or indebtedness" will be 5.02% for the fourth quarter of 2013 - i.e. October 1, 2013
See MoreSpanish Government Approves DTA with United Kingdom
On 20 September 2013, the Ministry of Finance of Spain announced that the Council of Ministers has approved the agreement with the UK for the avoidance of double taxation and prevention of fiscal evasion with respect to income and equity. The new
See MoreNew Income and Capital Tax Treaty between Hungary and Switzerland
The Income and Capital Tax Treaty between Hungary and Switzerland was signed on 12 September 2013. After entering into force and becoming effective the new treaty will replace the existing Hungary – Switzerland Income and Capital Tax Treaty of
See MoreTreaty between Finland and Tajikistan enters into force
On 5 September 2013, the Finland- Tajikistan Income Tax Treaty (2012) entered into force. The treaty generally applies from 1 January 2014. The new treaty generally follows the provisions of the OECD Model Tax Convention. Under the provisions of
See MoreChina: Taxable presence of foreign entity’s seconded workers
Recently a guidance concerning when the cross-border secondment of expatriate workers by foreign enterprises into China may give rise to a taxable presence in China is issued by the China’s State Administration of Taxation. Factors taken into
See MoreGermany: Amendments to the taxation of portfolio dividends
A new law in respect of dividend taxation was published in the Federal Gazette on 21 March 2013. This law has been introduced following a decision of the European Court of Justice in 20 October 2011 which required a review of the taxation of
See MoreFrance-Modification to capital gains tax regime
The President of France announced on 29 April 2013 that the tax regime on capital gains is to be modified. To encourage entrepreneurship the government will simplify the different existing regimes. Since 1 January 2013, occasional capital gains on
See MoreTreaty between Ireland and Ukraine signed
Ireland and Ukraine signed a Double Tax Agreement on 19 April 2013. This DTA represents an important step in boosting trade relations between Ireland and Ukraine. The treaty will enter into force when the relevant ratification procedures have been
See MoreIndia and Malta have signed a new Double Taxation Avoidance Agreement
India and Malta have signed a new Double Taxation Avoidance Agreement (DTAA) on April 8 2013. The provisions of the treaty generally follow the provisions of the OECD Model but the definition of a permanent establishment includes a building site or
See MoreTreaty between Cyprus and Finland enters into force
On 28 April 2013, the double tax agreement that was signed on 15 October 2012 between Cyprus and Finland will enter into force. The treaty generally follows the provisions of the OECD Model. Under the treaty the maximum withholding tax rate on
See MoreTreaty between Albania and United Kingdom signed
On 26 March 2013, Albania and the United Kingdom signed a Double Taxation Agreement. The agreement generally follows the provisions of the OECD Model, with some modifications. The agreement will enter into force when the appropriate ratification
See MoreTreaty between US and Poland signed
United States has signed an Income Tax Treaty (2013) with Poland on 13 February 2013 which will replace the existing agreement, signed 1974. The new treaty provides for reductions in withholding taxes on cross-border payments of dividends,
See MoreTax treaty signed between Germany and Oman
A double taxation treaty between Germany and Oman was signed in Muscat on 15 August 2012. This follows the conclusion of a bilateral investment promotion and protection treaty which was signed in 2010. The double taxation treaty generally follows
See MoreLatvia –Mexico: Treaty enter into force
The treaty between Latvia and Mexico for the avoidance of double taxation which was signed on 20 April 2012 is to enter into force on 2 March 2013. The maximum withholding tax on dividends is 10%, reduced to 5% where the recipient company is the
See MoreTreaty between Barbados and United Kingdom enters into force
The Double Taxation Agreement between Barbados and the United Kingdom entered into force on 19 December 2012 which was signed in Barbados on 26 April 2012. The Double Taxation Agreement generally follows the provisions of the OECD Model; however
See MoreTax treaty between Hong Kong and Italy has been signed
Hong Kong has signed an agreement on 14 January 2013 with Italy for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement generally follows the provisions of the OECD Model and has
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