OECD: Peer Review Reports on Making Tax Dispute Resolution More Effective
On 14 April 2022 the OECD published a further set of peer review reports under BEPS Action 14 which is concerned with making tax dispute resolution mechanisms more effective. These reports set out the results of assessments under stage two of the
See MoreTax Treaty News: April 2022
Chile and US On 29 March 2022, the United States (US) Senate approved the Double Taxation Agreement (DTA) with Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Guyana
See MoreEU: Pressure on member states to revise CBI/RBI schemes
Recently there has been increased pressure on European Union (EU) member states to scale back their schemes offering citizenship or residence in return for financial contributions. This reflects heightened security concerns in view of the current
See MoreWTO: Trade Review of UAE
From 22 to 24 March 2022 the World Trade Organisation (WTO) conducted a review of the trade policies and practices of the United Arab Emirates (UAE). As a basis for the review, a report was prepared by the WTO Secretariat. The UAE’s economy
See MoreOECD: Fourth Peer Review Report on Prevention of Tax Treaty Abuse
On 21 March 2022 the OECD released the fourth peer review report on tax treaty abuse under Action 6 of the action plan on base erosion and profit shifting (BEPS). The report looks at the measures that member countries of the OECD’s
See MoreTax Treaty News: March 2022
Cambodia and Turkey On 27 February 2022, the Double Taxation Agreement (DTA) between Cambodia and Turkey was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Israel and
See MoreEU: Joint European Action for Affordable and Sustainable Energy
On 8 March 2022 the European Commission issued a communication entitled REPowerEU: Joint European Action for more affordable, secure and sustainable energy. This document notes that the current geopolitical situation requires independence from
See MoreEU: European Parliament Adopts Resolution on Impact of National Tax Schemes
On 15 February 2022 the European Parliament adopted a resolution relating to the impact of national reforms on the economy of the European Union. Resolutions of the European Parliament are not binding on other EU institutions, but they call for
See MoreTax Treaty News: February 2022
Sri Lanka and Turkey On 28 January 2022, the Double Taxation Agreement (DTA) between Sri Lanka and Turkey was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Argentina
See MoreEU: Role of Environmental Taxation in Supporting the Transition to Sustainability
On 7 February 2022 the European Environment Agency (EEA) issued a briefing entitled The role of environmental taxation in supporting sustainability transitions. This examines trends in taxes on pollution, greenhouse gases and resource use and
See MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreOECD: Stage Two Peer Review Report on Jersey under BEPS Action 14
On 24 January 2022 the OECD’s Inclusive Framework published the stage 2 peer review report on Jersey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreOECD: Stage Two Peer Review Report on Serbia under BEPS Action 14
On 24 January 2022 the OECD’s Inclusive Framework released the stage 2 peer review report on Serbia’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). The minimum standard under
See MoreTax Treaty News: January 2022
Sweden and UK On 31 December 2021, the amending protocol to the Double Taxation Agreement (DTA) between Sweden and the United Kingdom (UK) entered into force. The protocol applies from 1 January 2022. Kosovo and Netherlands On 31
See MoreTurkey sets 0% withholding tax rate on certain TRY deposit accounts
On 31 December 2021, Turkey has published Presidential Decision No. 5046 in Official Gazette. Accordingly, Turkey has set 0% withholding tax will be applicable on income from certain TRY deposit accounts and participation accounts. As of 28
See MoreCanada CRA publishes a notice regarding the effect of MFN provisions with Lithuania
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on the Most Favoured Nation (MFN) provision of the Canada–Lithuania Income Tax Convention with respect to certain royalties. Effective January 1, 2019, the
See MoreCanada: CRA publishes a notice regarding the effect of MFN provisions with Latvia
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on Most Favoured Nation (MFN) provision of the Canada–Latvia Income Tax Convention with respect to certain royalties. Effective January 1, 2018, the
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
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