US and Israel sign agreement on the exchange of CbC reports
The Internal Revenue Service (IRS) of the United States has released the competent authority arrangement concerning exchanging Country-by-Country (CbC) Reports with Israel. As per the IRS CbC Reporting Jurisdiction Status Table, this arrangement
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Armenia ratifies MCCA on the exchange of financial account information
On 3 October 2023, the President of Armenia, Vahagn Khachaturyan, signed the law to ratify the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information (MCAA). This agreement facilitates the exchange
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Tax Treaty Brief: September 2023
Bangladesh and Hong Kong On 30 August 2023, the Govt. officials from Bangladesh and Hong Kong signed a Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
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Hong Kong and Bangladesh enter into tax pact
On 30 August 2023, 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 Bangladesh.
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ASEAN Requests a Review of the Global Minimum Tax
On 19 August 2023, at the ASEAN Economic Ministers' meeting, the Chair of the ASEAN Investment Area (AIA) Council called for a review of the global minimum tax that is being implemented under Pillar Two of the OECD two-pillar international tax
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Tax Treaty Brief: August 2023
Albania and Slovak Republic On 26 July 2023, the Council of Ministers in Albania approved the draft legislation for the ratification of the Double Taxation Agreement (DTA) with the Slovak Republic. Germany and Switzerland On 26 July
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OECD: Facilitating the Use of Treaty Exchanged Information for Non-Tax Purposes
Sharing of treaty-exchanged information with relevant law enforcement agencies for non-tax purposes helps to combat illicit financial flows (IFFs), money laundering and corruption. Institutions often face operational challenges in implementing this
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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
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WTO 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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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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