US: IRS clarifies mutual agreement procedure relief requirements under tax treaty with Germany
The IRS Office of Chief Counsel (OCC) issued a letter on 11 April, 2024, addressing an inquiry regarding the 1989 US-Germany income tax treaty. The letter outlines the requirements for obtaining tax relief under Article 25 (Mutual Agreement
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Montenegro ratifies tax treaty with Luxembourg
The Parliament of Montenegro announced the passage of the law to ratify the income and capital tax treaty with Luxembourg on 31 July 2024. This treaty, signed on 29 January 2024, marks the first formal tax agreement between the two nations. This
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Kazakhstan ratifies free trade and investment agreement with Singapore
The President of Kazakhstan Kassym-Jomart Tokayev signed Law No. 125-VIII ZRK ratifying the agreement on free trade in services and investments with Singapore on 16 July 2024. The newly enacted law is designed to strengthen trade and economic
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Mexico, US renew maquiladora tax agreement
The Mexican Tax Administration (SAT) announced the second renewal of the Qualified Maquiladora Approach Agreement (QMA) with the US Internal Revenue Service (IRS). The SAT stated that the latest renewal preserves the core aspects of the QMA's
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Iran, Saudi Arabia finalise income tax treaty negotiations
Iran and Saudi Arabia have successfully concluded their fourth round of negotiations for an income tax treaty, which took place from 12 to 14 July, 2024. This agreement aims to eliminate double taxation and enhance economic cooperation, providing
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Saudi Arabia, Kuwait to sign first income tax treaty
The Saudi Council of Ministers authorised the signing of an income tax treaty with Kuwait on 23 July 2024. This will be the first tax treaty between the two Gulf nations once finalised, signed and ratified. The treaty aims to eliminate double
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Netherlands ratifies pending Curacao-Malta tax treaty
The Netherlands published the Law of 27 July 2024 in the official gazette, on 25 July 2024, ratifying the pending income tax treaty between Curaçao and Malta. The treaty aims to prevent double taxation and eliminate fiscal evasion regarding income
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Netherlands: Curaçao, Suriname sign tax treaty
The Netherlands announced in the Official Gazette on 25 July, 2024, that it signed a tax treaty to prevent double taxation between Curaçao and Suriname. As a constituent country of the Kingdom of the Netherlands, Curaçao can negotiate bilateral
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Korea (Rep.), Turkey income tax treaty enters into force
The new income tax treaty between Korea (Rep.) and Turkey entered into force on 21 July 2024, replacing the 1983 treaty between the two countries. It aims to enhance tax cooperation and prevent double taxation between the two nations in line with
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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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Costa Rica, Switzerland to restart tax treaty talks
The Swiss Federal Council, in a release on 15 July 2024, has announced that Costa Rica and Switzerland officials have restarted negotiations for an income tax treaty between the two countries. Officials from both nations discussed bilateral and
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Azerbaijan publishes law on ratification of pending tax treaty with Kyrgyzstan
Azerbaijan published the law – titled, “Law of the Republic of Azerbaijan on approval of the ‘Agreement between the Republic of Azerbaijan and the Kyrgyz Republic on the elimination of double taxation and prevention of tax evasion with respect
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Switzerland, Hungary sign protocol to update double taxation agreement
Switzerland and Hungary signed a protocol of amendment to the agreement for the avoidance of double taxation with respect to taxes on income and capital (DTA) on 12 July 2024 at Budapest. It implements the minimum standards for double taxation
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Egypt approves tax treaty with Oman
The Egyptian Cabinet approved the ratification of the income tax treaty with Oman on 9 July 2024. Signed on 22 May 2023, the treaty specifies that dividends, royalties, and fees for technical services are liable to a maximum withholding tax rate
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Belgium publishes synthesised text of treaty with South Africa impacted by MLI
The Belgian Federal Public Service Finance published on 24 June, 2024, a synthesised text in English of the 1995 Double Taxation Agreement (DTA) between Belgium and South Africa, detailing the impact of the Multilateral agreement to Instrument Tax
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Tax treaty between Luxembourg, Rwanda enters into force
The income and capital tax treaty between Luxembourg and Rwanda has entered into force starting 14 February 2024, it was published in Journal Officiel du Grand-Duché de Luxembourg (No. A277) on 4 July 2024. The agreement states that dividends,
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Malta, Romania sign amending protocol to tax treaty
Malta and Romania signed an amending protocol to the 1995 Malta-Romania Income Tax Treaty on 4 July, 2024, aiming to enhance the original tax treaty between the two countries on the avoidance of double taxation and the prevention of fiscal
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Estonia approves signing draft tax treaty with Botswana
Estonia’s government has approved signing an income tax treaty with Botswana on 4 July, 2024. The tax treaty seeks to eliminate double taxation, and prevent tax evasion. If an agreement is reached, it will be a first between the two
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