OECD: Discussion draft on treaty residence of pension funds
On 29 February 2016 the OECD issued a discussion draft on the tax treaty residence of pension funds. Changes are to be made to the OECD Model to ensure that a recognized pension fund is treated for the purpose of the tax treaty as resident in the
See MoreUK: Annual report on code of practice for banks
The Code of Practice on Taxation for Banks was published in December 2009. This voluntary Code of Practice was a non-statutory statement of principles on bank governance, openness and attitudes to tax planning. The larger financial institutions are
See MoreSaudi Arabia-publishing of new Companies Law
The Ministry of Commerce and Industrial declared on 9 November 2015 that the new Companies Law (NCL) will come into force after 150 days of its publication in the Saudi Official Gazette. According to the new law only one shareholder will be able to
See MoreUK: Pension changes for individuals who already have an annuity
The UK has announced that measures announced last year to give more choice to individuals on how to use their pension fund will be extended to people who already have an annuity. With effect from April 2016 the restrictions on buying and selling
See MoreHong Kong: Government Renews Anti-Money Laundering Guidelines
Hong Kong has gazetted an anti-money laundering amendment notice that will allow its financial institutions to continue to delegate customer due diligence (CDD) functions. The Anti-Money Laundering and Counter-Terrorist Financing (Financial
See MoreFinland: Uniform Tax Treatment Of Pension Benefits For Foreign Entities And Finnish Pension Institutions
Starting 2015, and subject to certain restrictions, foreign corporate entities comparable to Finnish pension institutions are entitled to a similar deduction. Under the provisions of Business Tax Act, Finnish pension institutions may deduct the
See MoreUS: Issues final regulation TD 9707 to provide guidance on the requirements to file IRS Form 5472
Final regulations TD 9707 provide guidance on the filing requirements for Form 5472 which is the information return for a 25% foreign owned US corporations or a foreign corporation engaged in a US trade or business. Final regulations TD 9707 is
See MoreCzech Republic – Pending changes regarding VAT, investment fund managers
In Czech Republic, draft legislative or pending proposals contain: Revise of the income tax law proposes to allow for the waiver of penalties and interest Proposal of requiring a “review statement” listing information on taxable supplies
See MoreTaiwan: Ministry of Finance improved business tax for banks, insurance companies
Taiwan’s Government has increased business tax for banking and insurance industries from 2% to 5%, which will be effective on 1 July 2014. Nevertheless, a 2% rate may remain to apply for banks and insurance companies that involve in the essential
See MoreEU – Refund opportunities for non-EU investment funds
A recent decision of the European Court of Justice (ECJ) may give a chance to some non-EU investment funds to obtain a withholding tax refund. The ECJ decision in Emerging Markets Series of DFA Investment Trust Company, C-190/12 (10 April 2014), was
See MoreSingapore – Employer contributions to overseas pension funds
The Inland Revenue Authority of Singapore (IRAS) has issued information on its website explaining amended rules relating to the concessionary tax exemption available for contributions by employers to certain pension schemes. The exemption relates to
See MoreTax on non-resident pension funds in Finland held to be discriminatory
The European Court of Justice (ECJ) has ruled that a tax on dividends received by non-Finnish pension funds in Finland is discriminatory. Currently, resident pension funds can avoid paying tax on dividends from investments by transferring such
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