Tax Treaty News: August 2019

Indonesia and UAE	On 24 July 2019, Indonesia and the United Arab Emirates (UAE) signed an amending protocol to the Double Taxation Agreement (DTA) in Jakarta.
Ukraine and UAE	On 24 July 2019, the Cabinet of Ukraine approved to sign an amending protocol to the Double Taxation Agreement (DTA) with United Arab Emirates (UAE).
Ukraine and Oman	On 24 July 2019, the Cabinet of Ukraine authorized to sign a Double Taxation Agreement (DTA) with Oman.
Kosovo and Luxembourg	On 23 July 2019, the Double Taxation Agreement (DTA) between Kosovo and Luxembourg was entered into force and applies from 1 January 2020.
Kosovo and Malta	On 23 July 2019, the tax administration of Malta published a Gazette No. 20,236 announcing Malta has ratified the Double Taxation Agreement (DTA) with Kosovo.
Botswana and Kenya	On 23 July 2019, the Double Taxation Agreement (DTA) between Botswana and Kenya was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Nairobi.
China and Hong Kong	On 19 July 2019, Hong Kong and China have signed the Fifth Protocol to the Double Taxation Agreement (DTA) which provides tax relief to qualified Hong Kong and China teachers and researchers as well as it also incorporates measures to prevent tax treaty abuse, which form part of the Base Erosion and Profit Shifting (BEPS) package promulgated by the OECD.
Belarus and Sudan	On 18 July 2019, Belarus ratified the Double Taxation Agreement (DTA) with Sudan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
US, Switzerland, Luxembourg, and Japan	On 17 July 2019, the United States (US) Senate approved the amending protocol to the Double Taxation Agreement (DTA) with Switzerland, Luxembourg, and Japan.
Spain and US	On 16 July 2019, the United States (US) Senate approved the amending protocol to the Double Taxation Agreement (DTA) with Spain.
Luxembourg and Uzbekistan	On 12 July 2019, Luxembourg ratified the amending protocol to the Double Taxation Agreement (DTA) with Uzbekistan.
Luxembourg and Kosovo	On 12 July 2019, Luxembourg ratified the Double Taxation Agreement (DTA) with Kosovo. Once in force and effective, the new DTA will replace the former DTA of 1958.
Luxembourg and Belgium	On 12 July 2019, Luxembourg ratified the amending protocol to the Double Taxation Agreement (DTA) with Belgium.
Luxembourg and France	On 12 July 2019, Luxembourg ratified the Double Taxation Agreement (DTA) with France. Once in force and effective, the new DTA will replace the former DTA of 1958.
US and Switzerland	On 10 July 2019, the United States (US) Committee on Foreign Relations has released an executive report (116-2) regarding the amending protocol to the Double Taxation Agreement (DTA) with Switzerland. The protocol was approved by the US Senate on 17 July 2019.
UK and Israel	On 10 July 2019, the United Kingdom (UK) ratified the amending protocol to the Double Taxation Agreement (DTA) with Israel.
US and Spain	On 10 July 2019, the United States (US) Committee on Foreign Relations has released an executive report (116-1) regarding the amending protocol to the Double Taxation Agreement (DTA) with Spain. The protocol was approved by the US Senate on 17 July 2019.
UK and Cyprus	On 10 July 2019, the United Kingdom (UK) ratified the amending protocol to the Double Taxation Agreement (DTA) with Cyprus.
US and Luxembourg	On 10 July 2019, the United States (US) Committee on Foreign Relations has released an executive report (116-4) regarding the amending protocol to the Double Taxation Agreement (DTA) with Luxembourg. The protocol was approved by the US Senate on 17 July 2019.
US and Japan	On 10 July 2019, the United States (US) Committee on Foreign Relations has released an executive report (116-3) regarding the amending protocol to the Double Taxation Agreement (DTA) with Japan. The protocol was approved by the US Senate on 17 July 2019.
Armenia and Singapore	On 8 July 2019, the Double Taxation Agreement (DTA) between Armenia and Singapore was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Singapore. The agreement contains Dividends rate 0% for at least 25% capital holding or investment at least USD 300,000; otherwise 5%, Interest rate 5%, and Royalties rate 5%.
Czech Republic and Sri Lanka	On 8 July 2019, the Czech government approved to sign the Double Taxation Agreement (DTA) with Sri Lanka. Once in force and effective, the new DTA will replace the former DTA of 1978.
Armenia and Singapore	On 4 July 2019, the government of Armenia approved to sign a Double Taxation Agreement (DTA) with Singapore.
Belarus and UAE	On 3 July 2019, the Ministry of Foreign Affairs of the United Arab Emirates (UAE) declared that, the Cabinet has approved the amending protocol to the Double Taxation Agreement (DTA) with Belarus.
Luxembourg and Uzbekistan	On 2 July 2019, the Chamber of Deputies of Luxembourg approved the amending protocol of Double Taxation Agreement (DTA) with Uzbekistan.
Luxembourg and Belgium	On 2 July 2019, the Chamber of Deputies of Luxembourg approved the amending protocol of Double Taxation Agreement (DTA) with Belgium.
Luxembourg and Kosovo	On 2 July 2019, the Chamber of Deputies of Luxembourg approved the Double Taxation Agreement (DTA) with Kosovo.
Luxembourg and France	On 2 July 2019, the Chamber of Deputies of Luxembourg approved the Double Taxation Agreement (DTA) with France. Once in force and effective, the new DTA will replace the former DTA of 1958.
Iraq and Netherlands	On 1 July 2019, the Double Taxation Agreement (DTA) between Iraq and the Netherlands was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Baghdad. The agreement contains Dividends rate 0% for at least 10% capital holding; otherwise 15%, Interest rate 5%, and Royalties rate 7.5%.
Chile, Japan, Australia, and Uruguay	On 28 June 2019, the tax authority of Chile issued Circular No. 27/2019, clarifying the impact of the Double Taxation Agreement (DTA) with Japan on the MFN clauses contained in the DTA with Australia and Uruguay. The withholding rate for interest has been reduced from 15% to 10% in the DTA with Australia, effective from 1 January 2019. The MFN clause on interest of the DTA with Uruguay has not been activated because the DTA was signed after the agreement with Japan.
Chile, Argentina, France, and Sweden	On 28 June 2019, the tax authority of Chile issued Circular No. 27/2019, declaring that the conditions for activation of the most favored nation (MFN) clause in the Double Taxation Agreement (DTA) with Argentina, France and Sweden have been met. The conditions were met with the entry into force of the DTA between Chile and Japan. The new rates are applicable as from 1 January 2017 for France and Sweden and from 1 January 2019 for Argentina.
Chile, China, and Japan	On 28 June 2019, the tax authority of Chile issued Circular No. 27/2019, declaring that the maximum withholding tax rate for interest is 10% contained article 11(2)(b) of the Double Taxation Agreement (DTA) with China as well as Japan has effect from 1 January 2019. As per article 11(3) of the DTAs, a rate of 15% was applicable for 2 years since 1 January 2017.
Belgium and Lithuania	On 27 June 2019, Circular No. 2019/C/55 was published clarifying the MFN clause contained in the final protocol to the Double Taxation Agreement (DTA) between Belgium and Lithuania has triggered due to the DTA between Japan and Lithuania. Accordingly, the withholding tax rate for royalties under the DTA between Belgium and Lithuanian is 0% with effect from 1 January 2019.
Albania and Saudi Arabia	On 20 June 2019, Albania has ratified the Double Taxation Agreement (DTA) with Saudi Arabia. The agreement contains Dividends rate 5%, Interest rate 10%, and Royalties rate 5% on payment for the use of, or the right to use, industrial, commercial, or scientific equipment; otherwise, 8%.
Norway and Switzerland	On 20 June 2019, Switzerland and Norway signed a protocol of amendment to the Double Taxation Agreement (DTA), in Oslo. In particular, the protocol of amendment contains an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused.
Switzerland and Zambia	On 7 June 2019, the Double Taxation Agreement (DTA) between Switzerland and Zambia was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 5% for at least 10% capital holding; otherwise 15%, Interest rate 10%, and Royalties rate 5%. From 1 January 2020, the new DTA will replace the former DTA of 1954.
China and India	On 5 June 2019, the amending protocol to the Double Taxation Agreement (DTA) between China and India was entered into force and applies from 1 January 2020 for China and from 1 April 2020 for India.
Croatia and Vietnam	On 23 May 2019, the Double Taxation Agreement (DTA) between Croatia and Vietnam was entered into force and applies from 1 January 2020. The agreement contains Dividends rate 10%, Interest rate 10%, and Royalties rate 10%.
Indonesia and Mexico	On 29 April 2019, Indonesia has ratified the amending protocol to the Double Taxation Agreement (DTA) with Mexico.
Israel and Macedonia	On 13 March 2019, the Double Taxation Agreement (DTA) between Israel and Macedonia was entered into force and applies from 1 January 2019. The agreement contains Dividends rate 5% for at least 25% capital holding; otherwise 15%, Interest rate 10%, and Royalties rate 5%.