Tax Treaty Brief: July 2023
Cyprus and Netherlands On 30 June 2023, the Double Taxation Agreement (DTA) between Cyprus and the Netherlands entered into force. The DTA contains withholding tax rates for Dividends 0% for at least 5% capital holding; otherwise, 15%,
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Tax Treaty Brief: June 2023
Slovenia and Switzerland On 30 May 2023, Slovenia and Switzerland officially signed an amending protocol to update the Double Taxation Agreement (DTA) between the two nations. The primary objective of this protocol is to ensure that the DTA
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UK: Consultation on Changes to Transfer Pricing Rules
On 19 June 2023 the UK government launched a consultation on potential reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax. Transfer Pricing - provision Currently section 147 TIOPA refers to a
See MoreWTO Trade Policy Review of EU
The WTO is reviewing the trade policies and practices of the EU on 5 and 7 June 2023. The WTO Secretariat has produced a report as a basis for the review. During the period under review the EU made progress on major policy initiatives including
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Russia suspends DTAs with 38 unfriendly countries
The Russian Ministry of Foreign Affairs has declared to suspend application of double tax agreements (DTAs) with unfriendly 38 countries that have introduced unilateral economic restrictions against Russia. The potential repercussions entail
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Tax Treaty Brief: May 2023
Hong Kong and Mauritius On 26 April 2023, the Chief Executive in Council of Hong Kong issued an Order to implement the provisions of the Double Taxation Agreement (DTA) with Mauritius. Czech Republic and Kosovo On 20 April 2023, the
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EU: European Commission Announces Proposals for Customs Reform
On 17 May 2023 the European Commission set out proposals for a reform of the EU Customs Union. The proposals are a response to the large increase in the volume of trade in recent years, the growth in e-commerce and the need to enforce EU trading
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Tax Treaty Brief: April 2023
Denmark and France On 28 March 2023, Denmark ratified the new Double Taxation Agreement (DTA) with France, as published in the Danish official gazette. The DTA contains withholding tax rates for Dividends 0% for at least 10% capital holding;
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US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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OECD: Peer Review Report on the Prevention of Treaty Shopping
On 21 March 2023 the OECD released the latest peer review results following assessment of the actions taken by each country to prevent tax treaty shopping under BEPS Action 6. The Fifth Peer Review Report on Treaty Shopping assesses the
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Tax Treaty Brief: March 2023
Andorra and Iceland On 28 February 2023, the Double Taxation Agreement (DTA) between Andorra and Iceland was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Egypt and
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Germany publishes list of Jurisdictions for Automatic Exchange of Information
On 23 February 2023, the German Ministry of Finance has released an updated list of jurisdictions that will receive financial account information automatically for tax purposes starting on 30 September 2023. For 2023, six new countries have been
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Tax Treaty Brief: February 2023
Belarus and Zimbabwe On 31 January 2023, the Double Taxation Agreement (DTA) between Belarus and Zimbabwe was signed. The DTA contains withholding tax rates for Dividends 5% for at least 20% capital holding; otherwise, 15%, Interest 10%, and
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OECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
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Tax Treaty News: January 2023
Austria and United Arab Emirates On 1 March 2023, the amending protocol to the Double Taxation Agreement (DTA) between Austria and the United Arab Emirates (UAE) will enter into force. The protocol generally applies from 1 January
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Tax Treaty News: December 2022
Chile and Netherlands On 30 November 2022, the Double Taxation Agreement (DTA) between Chile and Netherlands entered into force. The DTA contains withholding tax rates for Dividends 5% for at least 25% capital holding; otherwise, 15%,
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WTO: Lessons learned from the pandemic
On 21 November 2022 the WTO’s Committee on Market Access held the fifth of a series of experience-sharing sessions on trade in goods related to the pandemic. The session looked at the main lessons learned from the pandemic and was preceded by a
See MoreGlobal Forum Plenary Meeting
On 9 to 11 November 2022 the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) held its 15th Plenary Meeting. The main theme of the discussions was to bring transparency and exchange of information to the
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