The Finance Minister of Algeria has announced that representatives of Algeria and the Netherlands met on 31st July 2017 to discuss bilateral relations and strengthening the relationship through the conclusion of an income tax treaty. The treaty must be finalized after negotiation, signed, and ratified before entering into force.
Argentina and Brazil signed an amending protocol to the, Argentina – Brazil Income Tax Treaty of 1980 on 21st July 2017. The protocol sets out maximum levels of taxation at source in specific categories of income; modifies the method to avoid double taxation in Argentina, and inserts a capital gains article into the treaty.
The Ministry of Finance on 28 July 2017 has issued a Notification (No. 75/2017), which announces that the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country (CbC) Reports entered into force for India on 12 May 2016 and is effective between India and other jurisdictions.
The amnesty on interest and penalties which was introduced by the Zambia Revenue Authority (ZRA) on 24th April 2017, came to a close on 31st July 2017.
During this period, taxpayers were expected to submit outstanding tax returns and pay all principal tax liabilities for tax periods prior to 1st March 2017, after which all interest and penalties accrued for the said period would be waived in full. Taxpayers were expected to pay all outstanding principal liabilities within the amnesty period. In instances where taxpayers have not been able to settle the principal liabilities before 31st July 2017, the ZRA has offered an opportunity of settling such tax liabilities in installments by entering into Time-to-Pay-Agreements (TPAS) with taxpayers to be settled before 31st December 2017.
Notwithstanding this extension, the deadline for time-to-pay agreements remains 31st December, 2017 and all other rules will remain as announced by the commissioner general during the launch of the amnesty campaign on 24th April, 2017
On 11 August 2017 the US IRS in its latest bulletin of news and information on country by country (CbC) reporting advised that parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual reporting period can now file Form 8975, Country-by-Country Report, with their annual income tax return.
Form 8975, and attached Schedules A, will report a U.S. MNE group’s income, taxes paid, and other indicators of economic activity on a country-by-country basis.
According to an IRS announcement on its website, the competent authorities of the U.S. and Estonia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is on the basis of a double tax convention (DTC). The agreement was signed on 26 July 2017.
Under the arrangement, the first fiscal year for which the U.S. and Estonia intend to exchange CbC reports is the fiscal years of MNE Groups commencing on or after January 1, 2016. The CbC report is intended to be exchanged as soon as possible and no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates. CbC reports with respect to fiscal years of MNE Groups commencing on or after January 1, 2017 are intended to be exchanged as soon as possible and no later than 15 months after the last day of the fiscal year of the MNE Group to which the CbC report relates.
The Competent Authorities intend to exchange the CbC Reports automatically through a common schema in Extensible Markup Language (XML).