Japan and Austria | On 30 January 2017, the Double Taxation Agreement (DTA) between Austria and Japan was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Vienna. Once in force and effective, the new treaty will replace the existing DTA of 1961. |
Hungary and Luxembourg | On 26 January 2017, the Double Taxation Agreement (DTA) between Hungary and Luxembourg was entered into force. This treaty will apply from 1 January 2018. From this date, the new treaty will replace the existing DTA of 1990. |
Moldova and Russia | On 25 January 2017, the State Tax Service (STS) of Moldova clarified the application of the Double Taxation Agreement (DTA) with Russia relating to the income derived by a resident of Russia from the sale of 60% of shares in the capital of a resident of Moldova to another resident of Moldova. According to article 13 of the DTA, gains from the alienation of any property, other than that referred to in paragraphs 1, 2, 3 and 4, will be taxable only in the state of which the alienator is a resident. So, income derived by the resident of Russia from the alienation of shares may be taxed only in Russia and accordingly, when purchasing shares from a resident of Russia, a resident of Moldova should not withhold any income tax, as stipulated in article 91 of the Tax Code. |
Panama and Vietnam | On 23 January 2017, the National Assembly of Panama approved the Double Taxation Agreement (DTA) with Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
UK and Estonia | Paragraph 7 of the Protocol to the double taxation agreement (DTA) of 1994 between Estonia and United Kingdom is the most favored nation (MFN) provision with regard to article 12 (royalties) of the treaty. The Protocol to DTA between Estonia and Switzerland provides for resident state taxation only with regard to royalties. On 18 January 2017, HMRC confirmed that the MFN provision has been triggered. With effect from 16 October 2015, no source state taxation is permitted under the DTA between Estonia and UK in respect of royalties. |
Brazil and Canada | On 18th January 2016, a Private Ruling 5/2017 has been published in the Official Gazette and it confirms that payments made by Brazilian sources to individual or companies resident in Canada for technical services provided, whether with or without the transfer of technology being incorporated, is subject to 15% withholding tax in Brazil. |
Brazil and US | According to Private Ruling 5/2017 of 18 January 2016, since there is no Double Taxation Agreement (DTA) signed between the United States and Brazil, income paid by Brazilian sources to individual or legal entities resident in the United States for technical services provided is subject to 15% withholding tax in Brazil in according with domestic legislation. |
India and Vietnam | According to a press release of Vietnamese government on 17 January 2017, Vietnam has approved the amending protocol of Double Taxation Agreement (DTA) with India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Czech Republic and Korea (Rep.) | On 16 January 2017, the government of the Czech Republic authorized to sign the Double Taxation Agreement (DTA) with Korea Republic. Once signed, in force and effective, the new treaty will replace the existing DTA of 1992. |
Paraguay and UAE | On 16 January 2017, the Double Taxation Agreement (DTA) between Paraguay and the United Arab Emirates was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Abu Dhabi. |
Belarus and Hong Kong | On 16 January 2017, the Double Taxation Agreement (DTA) between Belarus and Hong Kong was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Hong Kong. |
India and Kuwait | On 15 January 2017, India and Kuwait signed an amending protocol to Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Hungary and Oman | On 15 January 2017, Oman ratified the Double Taxation Agreement (DTA) with Hungary for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, by way of Royal Decree 6/2017. |
UAE and Belize | On 15 January 2017, the United Arab Emirates ratified the Double Taxation Agreement (DTA) with Belize that was signed on 2 October 2015, by way of Decree No. 230/2016. |
UAE and Comoros Islands | On 15 January 2017, the United Arab Emirates ratified the Double Taxation Agreement (DTA) with the Comoros Islands that was signed on 26 March 2015, by way of Decree No. 231/2016. |
UAE and Jordan | On 15 January 2017, the United Arab Emirates ratified the Double Taxation Agreement (DTA) with Jordan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, by way of Decree No. 224/2016. |
UAE and Macedonia | On 15 January 2017, the United Arab Emirates ratified the Double Taxation Agreement (DTA) with Macedonia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Italy and Barbados | On 12 January 2017, the Italian Senate approved the Double Taxation Agreement (DTA) with Barbados for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Italy and Philippines | On 12 January 2017, the Italian Senate approved the amending protocol of Double Taxation Agreement (DTA) with Philippines and that was signed on 9 December 2013. |
Hong Kong and Saudi Arabia | On 9 January 2017, the Saudi Arabian Cabinet authorized the Minister of Finance to sign the Double Taxation Agreement (DTA) with Hong Kong for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Albania and Iceland | On 6 January 2016, The Double Taxation Agreement (DTA) between Albania and Iceland was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. |
India and Kazakhstan | On 6 January 2017, India and Kazakhstan signed an amending protocol to Double Taxation Agreement (DTA) for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in New Delhi. |
Jersey and Seychelles | On 5 January 2017, the Double Taxation Agreement (DTA) between Jersey and Seychelles was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This treaty will apply from 1 January 2018. |
Cyprus and Iran | On 3 January 2017, the President of Iran signed a law ratifying the Double Taxation Agreement (DTA) with Cyprus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Iran and Slovak Republic | On 3 January 2017, the President of Iran signed a law ratifying the Double Taxation Agreement (DTA) with Slovak Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Azerbaijan and Sweden | On 31 December 2016, the Double Taxation Agreement (DTA) between Azerbaijan and Sweden was entered into force. The agreement generally applies from 1 January 2017. |
Kazakhstan and Slovenia | On 30 December 2016, the President of Kazakhstan signed a law ratifying the Double Taxation Agreement (DTA) with Slovenia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Hungary and Iran | On 30 December 2016, the Double Taxation Agreement (DTA) between Hungary and Iran was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. |
Poland and Taiwan | On 30 December 2016, the Double Taxation Agreement (DTA) between Poland and Taiwan was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement generally applies from 1 January 2017. |
Poland and Taiwan | According to Official Journal of 29 December 2016, Poland ratified the Double Taxation Agreement (DTA) with Taiwan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Armenia and Belarus | On 26 December 2016, the amending protocol of Double Taxation Agreement (DTA) between Armenia and Belarus was entered into force and that was signed on 19 May 2016. The protocol generally applies from 1 January 2017. |
UAE and UK | On 25 December 2016, the Double Taxation Agreement (DTA) between United Arab Emirates and United Kingdom was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. |
Belgium and Russia | On 23 December 2016, the Belgian Council of Ministers approved the Double Taxation Agreement (DTA) with Russia. The treaty will be subject to the approval of the parliaments and once in force and effective, the new treaty will replace the existing DTA of 1995. |
Hungary and Iraq | On 22 December 2016, the Hungarian government submitted a bill to parliament for the ratification of Double Taxation Agreement (DTA) with Iraq that was signed on 22 November 2016 in Budapest. |
India and Slovenia | On 21 December 2016, the amending protocol of Double Taxation Agreement (DTA) between India and Slovenia was entered into force and that was signed on 17 May 2016. This protocol will apply from 1 March 2017. |
Chile and Italy | On 20 December 2016, the Double Taxation Agreement (DTA) between Chile and Italy was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. |
Turkmenistan and UK | On 19 December 2016, the Double Taxation Agreement (DTA) between Turkmenistan and United Kingdom was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. From this date, the new treaty was replaced the existing DTA of 1985 and Transport Tax Treaty of 1974. |
Morocco and Slovenia | On 15 December 2016, Slovenia ratified the Double Taxation Agreement (DTA) with Morocco for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as published in Official Gazette of 30 December 2016. |
Luxembourg and Ukraine | On 14 December 2016, the Ukrainian Cabinet of Ministers approved the amending protocol of Double Taxation Agreement (DTA) with Luxembourg that was signed on 30 September 2016. The protocol has been submitted to the Ukrainian parliament for ratification. |
China and Macau | On 12 December 2016, the amending protocol of Double Taxation Agreement (DTA) between China and Macau was entered into force and that was signed on 19 July 2016. The protocol generally applies from 12 December 2016. |
Armenia and Belarus | On 12 December 2016, Belarus ratified the amending protocol of Double Taxation Agreement (DTA) with Armenia that was signed on 19 May 2016. |
South Africa and Zimbabwe | On 1 December 2016, the Double Taxation Agreement (DTA) between South Africa and Zimbabwe was entered into force. The treaty generally applies from 1 January 2017. From this date, the new treaty was replaced the existing DTA of 1965. |
Argentina and Mexico | On 23 November 2016, Argentina ratified the Double Taxation Agreement (DTA) with Mexico for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. |
Portugal and Vietnam | On 9 November 2016, the Double Taxation Agreement (DTA) between Portugal and Vietnam was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The treaty generally applies from 1 January 2017. |
China and Malaysia | On 1 November 2016, the exchange of letters to income tax treaty between China and Malaysia entered into force and this exchange of letters generally applies from 1 November 2016. |
China and Zimbabwe | On 29 September 2016, the Double Taxation Agreement (DTA) between China and Zimbabwe was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement generally applies from 1 January 2017. |
Tax Treaty News: January 2017
06 February, 2017