UK: 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
See MoreUK: Double tax treaty with Jersey enters into force
The double tax treaty between the UK and Jersey entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and Jersey for the avoidance of double taxation which ceases to have effect from the dates on which the
See MoreDTA between India and Hong Kong enters into force
On 30 November 2018, the tax treaty between India and Hong Kong entered into force and the treaty will be effective from 1 April 2019. The tax treaty provides for a low withholding tax rate of 5% for dividend payments. Interest, royalties, and fees
See MoreSingapore signs TIEA and FATCA with the US
On 13 November 2018, the Inland Revenue Authority of Singapore has confirmed the signing of a tax information exchange agreement (TIEA) and a reciprocal FATCA Intergovernmental agreement (FATCA IGA) with the United States. The TIEA will permit
See MoreVietnam: National Assembly ratifies the Trans-Pacific Partnership
On 12 November 2018 the National Assembly of Vietnam formally ratified the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP). The CPTPP is an open agreement that allows other countries to join after the deal takes effect
See MoreOECD: Guidance on synthesised texts clarifying the impact of the MLI
The OECD announced on 16 November 2018 that new guidance is available for the development of synthesised texts presenting a clear overview of the modifications by countries to their bilateral double tax treaties as a result of applying the
See MoreOECD: Taxpayer input invited on seventh batch of Dispute Resolution peer reviews
On 15 November 2018 the OECD issued a request for taxpayers to submit input in relation to the seventh round of stage 1 peer reviews under action 14 of the OECD/G20 action plan on base erosion and profit shifting (BEPS). Action 14 is concerned with
See MoreIMF working paper examines effects of tax treaties with investment hubs
An IMF working paper was released on 24 October 2018 entitled The Cost and Benefits of Tax Treaties with Investment Hubs: Findings from Sub-Saharan Africa. (Working Paper 18/227). Double tax treaties can affect returns to foreign investment through
See MoreEU: Investment protection agreement with Vietnam
On 17 October 2018 the European Commission adopted an investment protection agreement with Vietnam, at the same time as a free trade agreement. This paves the way for the final signature and conclusion of the investment protection agreement. Under
See MoreEU: Free trade agreement with Vietnam
On 17 October 2018 the European Commission adopted the free trade agreement (FTA) between the EU and Vietnam. The FTA has been presented for signature to the European Council. A factsheet on the FTA with Vietnam has also been issued and sets out the
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