German Upper House Approves MLI to Implement Tax Treaty Related BEPS Measures
On 6 November 2020 the Bundesrat (the upper house in the German parliament) gave its approval to ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the
See MoreTurkey: Parliament passes Law on certain tax amendments for 2021
On 11 November 2020, the Turkish Parliament approved Law No. 7256 on “Restructuring Public Receivables and Amending Certain Laws”, which was published on 17 November 2020 in the Official Gazette. With the aforementioned Law, finalized public
See MoreUS: IRS and Treasury issue final regulations on foreign tax credits
On 12 November 2020, the Internal Revenue Service and Treasury published in the Federal Register providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax re-determinations, foreign tax credit
See MoreCroatia: Government presents four tax reform Bills to Parliament
On 12 November 2020, the Croatian Parliament announced that the Government sent four tax reform Bills, which provide changes in corporate income tax, personal income tax, and value added tax (VAT). Some of the changes including the Bills are given
See MoreHong Kong: Chief Executive in Council make orders on CDTAs with Serbia and Georgia
On 21 October 2020, the Chief Executive in Council has made two orders under the Inland Revenue Ordinance (Cap. 112) to implement the Comprehensive Avoidance of Double Taxation Agreements (CDTAs) with Serbia and Georgia. The orders will be gazetted
See MoreUN: Tax Committee discusses UN Model Commentary Issues – PE, treatment of software, CIVs
A report by James R. Border, Law Office of James R Border P.A., Fort Lauderdale, Florida On 22 October 2020 the United Nations Committee of Experts on International Tax Matters addressed several items relating to the UN Model Tax Convention.
See MoreNigeria: President presents National Budget for 2021
On 8 October 2020, the President, Muhammadu Buhari, presented the National Budget for the year 2021 to a joint session of the National Assembly consisting of the Senate and the House of Representatives. The 2021 Budget is titled 'Economic Recovery
See MoreHong Kong and Georgia enter into tax pact
On 5 October 2020, 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 MoreRussia and Malta sign a protocol to amend the double tax treaty
On 1 October, the Russian Ministry of Finance reported that the Protocol to Russia - Malta DTT has been signed. In general dividend and interest WHT increases to 15%. However, there is a number of exceptions and in some cases current 5% dividend
See MoreDenmark: Tax Minister announces to exempt nonresident charitable organizations from WHT
On 14 September 2020, the Tax Minister announced that Government has a plan to release a Bill in December 2020 regarding the exemption of on non-resident charitable organizations from Danish withholding tax (WHT) on portfolio dividends. At present,
See MoreMexico: Executive Branch submits 2021 economic proposal to Congress
On 8 September 2020, the Mexican Executive Branch has submitted Economic Package for fiscal year 2021 including a proposal of Tax Reform. The proposed 2021 Tax Law clarifies income tax law, value-added tax (VAT) law, and federal tax code. Tax key
See MoreHong Kong and Russia sign an agreement for the exchange of CbC report
On 3 September 2020, the Russian Federal Tax Service has announced that Hong Kong and Russia signed an agreement on the exchange of Country-by-Country (CbC) reports for the 2017 and 2018 reporting years. For reporting fiscal years beginning on or
See MoreHong Kong and Serbia enter into tax pact
On 28 August, 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 Serbia. The
See MoreWTO issues update on accessions
On 1 September 2020 the World Trade Organisation (WTO) published an update on accession negotiations for countries aiming for membership of the organisation. The WTO currently has 164 member countries and covers 98% of world trade. The WTO
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreUN: Draft Model Treaty Provision on Digital Services
On 6 August 2020 the United Nations (UN) published draft Article 12B for the UN Model Double Taxation Convention, to provide for the allocation of taxable income from automated digital services. The draft Article states that income from
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See MoreCOVID 19: Poland further postpones withholding tax rules to 31 December 2020
On 24 June 2020, the Polish Ministry of Finance released a decree that further postponed the effective date of withholding tax rules for corporate income tax purposes. The new effective date is 31 December 2020. The withholding tax was originally
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