UK: Consultation on tax dispute resolution
On 2 July 2019 the UK government published for consultation draft Regulations to implement EU Council Directive 2017/1852 on tax dispute resolution mechanisms. Under the draft Regulations a stronger system of dispute resolution would be introduced
See MoreGeorgia and Italy sign MOU on implementation of APA and MAP practice
On 6th June, 2019 Mr. Paolo Valerio Barbantini, Deputy Director General of the Italian Revenue Agency, and Mr. Vakhtang Lashkaradze, Director General of the Revenue Service of Georgia, met in Tbilisi, Georgia, to sign the Memorandum of
See MoreArgentina modifies TP documentation requirements
On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for
See MoreDTA between Ukraine and Qatar enters into force
On 9 April 2019, the Double Taxation Agreement (DTA) between Ukraine and Qatar was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 5% for at least 10% capital holding; otherwise 10%, Interest rate
See MoreIndia: CBDT invites public comments on proposal to amend rules for profit attribution to PE
On 18 April 2019, the Central Board of Direct Taxes (CBDT) released the Committee’s report on profit attribution to a permanent establishment (PE) in India for public consultation, specifically requesting for comments on the conclusions and
See MoreUN: Proposed updates to Model Tax Convention
On 3 April 2019 a number of papers were released by the UN in advance of the meeting of the UN Committee of Experts on International Cooperation in Tax Matters planned for 23 to 26 April 2019. These papers included suggested amendments to the UN
See MoreIndonesia: MoF issues restrictions on new foreign tax credit rules
The Minister of Finance (MoF) of Indonesia published a regulation No. 192/PMK.03/2018 regarding the implementation of tax credits on overseas income. PMK-192 is more comprehensive than the previous regulation regarding foreign tax credits (FTC).
See MoreNicaragua publishes tax law for 2019
On 28 February 2019, Nicaragua issued tax amend law No.987 in the Official Gazette including notices of the amendment of applicable withholding tax rates. Major changes are summarized in below: Establishing the changes in the alternative
See MoreUK: Double tax treaty with Lesotho takes effect
The double tax treaty between the UK and Lesotho takes effect in relation to UK corporation tax for financial years beginning on or after 1 April 2019. The treaty was signed on 3 November 2016 and entered into force on 18 September 2018. Permanent
See MoreUK: Tax treaty negotiating priorities for 2019
On 4 March 2019 the UK government set out its tax treaty negotiating priorities for 2019, following discussions with representatives of business, government departments and other interested organisations and individuals. The work program has been
See MoreDTA between Azerbaijan and Turkmenistan enters into force
On 12 February 2019, the parliament of Azerbaijan approved the Double Taxation Agreement (DTA) with Turkmenistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreUK: Finance Act 2019 receives Royal Assent
The UK Finance Act 2019 received the Royal Assent on 12 February 2019. The Act includes some of the measures announced by the Chancellor in the Autumn Budget in October 2018. Annual Investment Allowance The Annual Investment Allowance (AIA) is being
See MoreAngola introduces amnesty measures with foreign technical and management services contracts
On 28 December 2018, Angola published Law no. 18/19 with the General State Budget for 2019. The main procedures are summarized as follows: The Special Contribution on technical support and management service contracts were maintained in 2019. The
See MoreEU: Free trade agreement with Japan enters into force
The EU-Japan free trade agreement has been ratified by both parties and enters into force on 1 February 2019. Under the agreement certain goods originating in Japan for import into the EU or originating in the EU for export to Japan may be eligible
See MoreChile: IRS clarifies Taxation of Dividends and Interest
Recently, the Internal Revenue Service (IRS) issued two separate Rulings 59 and 2546 to clarify the taxation of dividends and interest by resident and nonresident taxpayer. The two rulings separately discussed in below: Taxation of dividends Ruling
See MoreUK: New protocol to double tax agreement with Israel
On 11 January 2019 the UK and Israel signed a protocol to update the double tax agreement between the two countries, incorporating tax treaty related recommendations of the OECD project on base erosion and profit shifting (BEPS). The protocol will
See MoreUK: Double Tax Agreement with Guernsey in force
The comprehensive Double Taxation Agreement and Protocol between the UK and Guernsey was signed on 2 July 2018 entered into force on 7 January 2019. When the agreement is in effect in relation the 1955 Arrangement between Guernsey and the UK for the
See MoreUK: Double tax treaty with Isle of Man enters into force
The double tax treaty between the UK and the Isle of Man entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and the Isle of Man for the avoidance of double taxation which ceases to have effect from the
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