Tax Treaty News: October 2016

UAE and Liechtenstein	On 30 October 2016, the Emirati cabinet approved the income and capital tax treaty with Liechtenstein for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
UAE and Slovak Republic	On 30 October 2016, the Emirati cabinet approved the income tax treaty with Slovak Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Armenia and Serbia	On 26 October 2016, the Armenian Parliament ratified the income and capital tax treaty with Serbia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Armenia and Slovak Republic	On 26 October 2016, the Armenian Parliament ratified the income and capital tax treaty with Slovak Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
India and New Zealand	On 26 October 2016, India and New Zealand was signed an amending protocol of income tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in New Delhi.
Poland and Taiwan	On 21 October 2016, the income tax treaty between Poland and Taiwan was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Taipei.
Australia and Germany	On 20 October 2016, the International Tax Agreements Amendment Bill 2016 received Royal Assent as Act No. 64 of 2016, ratifying the income and capital tax treaty between Australia and Germany. Once in force and effective, the new treaty will replace the existing DTA of 1972.
Equatorial Guinea and UAE	On 19 October 2016, the income and capital tax treaty between Equatorial Guinea and the United Arab Emirates was signed, in Abu Dhabi.
Estonia and Vietnam	On 19 October 2016, Estonia ratified the income tax treaty with Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Jordan and Saudi Arabia	On 19 October 2016, the income tax treaty between Jordan and Saudi Arabia was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Riyadh.
Morocco and Rwanda	On 19 October 2016, the income tax treaty between Morocco and Rwanda was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Kigali.
Belarus and Kazakhstan	On 18 October 2016, Belarus ratified the amending protocol of income and capital tax treaty with Kazakhstan that was signed on 16 March 2016.
Italy and Chile	On 18 October 2016, the Italian Senate approved the income tax treaty with Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Italy and Panama	On 18 October 2016, the Italian Senate approved the income tax treaty with Panama for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Austria and Liechtenstein	On 17 October 2016, Austria and Liechtenstein was signed an amending protocol of income tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Vienna.
Germany and Turkmenistan	On 15 October 2016, the parliament of Turkmenistan approved the income and capital tax treaty with Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the new treaty will replace the existing DTA of 1981.
Brunei and Korea (Rep.)	On 14 October 2016, the income tax treaty between Brunei and Korea (Rep.) 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 2017.
Panama and Vietnam	On 14 October 2016, the Council’s Cabinet of Panama approved the income tax treaty with Vietnam that was signed on 30 August 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Kazakhstan and Serbia	On 14 October 2016, the President of Kazakhstan signed a law ratifying the income and capital tax treaty with Serbia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Georgia and Kyrgyzstan	On 13 October 2016, the income tax treaty between Georgia and Kyrgyzstan was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Georgia.
Australia and Germany	On 13 October 2016, the Australian parliament approved the income and capital tax treaty with Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the new treaty will replace the existing DTA of 1972.
Cambodia and China	On 13 October 2016, the income tax treaty between Cambodia and China (People’s Rep.) was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Cambodia.
Guernsey and Seychelles	On 12 October 2016, the income tax treaty between Guernsey and Seychelles was entered into force. This treaty will apply from 1 January 2017.
Belgium and Japan	On 12 October 2016, the income tax treaty between Belgium and Japan was signed in Tokyo. Once in force and effective, the new treaty will replace the existing DTA of 1968, as amended by the 1998 and 2010 protocols.
Bulgaria and Pakistan	On 12 October 2016, the Council of Ministers of Bulgaria authorized the Minister of Finance to negotiate and sign an income tax treaty with Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Ireland and Pakistan	On 11 October 2016, the income tax treaty between Ireland and Pakistan was entered into force. This treaty will apply from 1 January 2017 for Ireland and from 1 July 2017 for Pakistan. From these dates, the new treaty will replace the existing DTA of 1973.
Brunei and Kuwait	On 11 October 2016, Brunei and Kuwait was signed an amending protocol of income tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Bandar Seri Begawan, Brunei.
Argentina and Chile	On 11 October 2016, the income and capital tax treaty between Argentina and Chile 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 2017.
Jersey and Cyprus	On 11 October 2016, the States Assembly of Jersey approved the income tax treaty with Cyprus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Germany and Australia	On 11 October 2016, Germany ratified the income and capital tax treaty with Australia. Once in force and effective, the new treaty will replace the existing DTA of 1972.
Hong Kong and Romania	On 10 October 2016, the Romanian Senate approved the income tax treaty with Hong Kong for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Guernsey and United Kingdom	On 18 March 2016, the amending protocol of income tax treaty and exchange of letters, signed on 22 September 2015 by the United Kingdom and on 7 October 2015 by Guernsey, as amended by the 1994 and 2009 protocols, entered into force.
Austria and Liechtenstein	On 7 October 2016, the government of Liechtenstein approved the amending protocol income and capital tax treaty with Austria that was signed on 15 September 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Colombia and France	On 7 October 2016, France ratified the income and capital tax treaty with Colombia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Belarus and Kazakhstan	On 6 October 2016, the Upper Chamber of the Belarusian Parliament approved the amending protocol of income and capital tax treaty with Kazakhstan that was signed on 16 March 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Latvia and Cyprus	On 6 October 2016, Latvia ratified the income tax treaty with Cyprus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Latvia and Hong Kong	On 6 October 2016, Latvia ratified the income tax treaty with Hong Kong for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Belarus and Pakistan	On 5 October 2016, Belarus and Pakistan was signed an amending protocol of income tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Islamabad.
Finland and Sri Lanka	On 4 October 2016, the Sri Lankan Cabinet authorized the signing of the already initialled tax treaty with Finland. Once signed, in force and effective, the new treaty will replace the existing DTA of 1982.
Finland and Estonia	On 3 October 2016, the tax administration of Finland issued a press release regarding the income and capital tax treaty between Finland and Estonia. Accordingly, the most-favoured nation (MFN) clause under article 12(7) has been triggered. Instead of applying article 12(2) and (3) of the treaty, the following rules apply: 2. “However, such royalties are not taxed in the Contracting State in which they arise.” 3. “The term “royalties” as used in this Article means payments of any copyright of literary, artistic or scientific work, to including cinematograph films, use of, or the right to use the copyright and patent, trade mark, design or model, plan, secret formula or process, or experience; intellectual, commercial or scientific.” According to press release, Finland applies the 0% withholding tax on royalties with effect from 1 January 2016. Any excess withholding tax paid can be claimed back via a refund procedure.
Ethiopia and Saudi Arabia	On 1 October 2016, the income tax treaty between Ethiopia and Saudi Arabia 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 2017 for Saudi Arabia and from 8 July 2017 for Ethiopia.
Ethiopia and Slovak Republic	On 30 September 2016, the income tax treaty between Ethiopia and Slovak Republic was signed for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, in Ethiopia.
Azerbaijan and Sweden	On 30 September 2016, the Azerbaijani parliament approved the income tax treaty with Sweden for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Azerbaijan and Malta	On 30 September 2016, the Azerbaijani parliament approved the income tax treaty with Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Colombia and France	On 29 September 2016, the French Senate approved the income and capital tax treaty with Colombia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Finland and Portugal	On 29 September 2016, the Finnish government authorized the signing of the already initialled tax treaty with Portugal. Once signed, in force and effective, the new treaty will replace the existing DTA of 1970.
Finland and Sri Lanka	On 29 September 2016, the Finnish government authorized the signing of the already initialled tax treaty with Sri Lanka. Once signed, in force and effective, the new treaty will replace the existing DTA of 1982.
Liechtenstein and Andorra	On 29 September 2016, the parliament of Liechtenstein approved the income and capital tax treaty with Andorra for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Liechtenstein and Iceland	On 29 September 2016, the parliament of Liechtenstein approved the income and capital tax treaty with Iceland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Liechtenstein and UAE	On 29 September 2016, the parliament of Liechtenstein approved the income and capital tax treaty with United Arab Emirates for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Korea (Rep.) and Tajikistan	On 28 September 2016, the income tax treaty between Korea (Rep.) and Tajikistan 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 2017.
Chile and Czech Republic	On 27 September 2016, the Czech Republic ratified the income and capital tax treaty with Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Armenia and Germany	On 27 September 2016, the Armenian Constitutional Court approved the income and capital tax treaty with Germany that was signed on 29 June 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the new treaty will replace the existing DTA of 1981.
Armenia and India	On 27 September 2016, the Armenian Constitutional Court approved the amending protocol of income tax treaty with India that was signed on 27 January 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Belarus and Armenia	On 27 September 2016, the Armenian Constitutional Court approved the amending protocol of income tax treaty with Belarus that was signed on 19 May 2016 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Australia and Germany	On 23 September 2016, the German Federal Council approved the income and capital tax treaty with Australia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the new treaty will replace the existing DTA of 1972.
India and Korea (Rep.)	On 12 September 2016, the income tax treaty between India and Korea (Rep.) was entered into force. This treaty will apply from 1 January 2017 for Korea (Rep.) and from 1 April 2017 for India. From this date, the new treaty will replace the existing DTA of 1985.
Argentina and Chile	On 7 September 2016, Argentina ratified the income and capital tax treaty with Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Morocco and Mauritius	On 25 August 2016, Morocco ratified the income tax treaty with the Mauritius, by way of Royal Decree No. 1.16.135, as published in Official Gazette No. 6500 of 15 September 2016.
Morocco and Sao Tome and Principe	On 25 August 2016, Morocco ratified the income tax treaty with Sao Tome and Principe, by way of Royal Decree No. 1.16.136, as published in Official Gazette No. 6500 of 15 September 2016.
Morocco and Slovenia	On 25 August 2016, Morocco ratified the income tax treaty with Slovenia, by way of Royal Decree No. 1.16.143, as published in Official Gazette No. 6500 of 15 September 2016.
Mali and Monaco	On 1 August 2016, the income tax treaty and amending protocol between Mali and Monaco was entered into force for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This treaty and the amending protocol will apply from 1 January 2017.
Turkey and Belgium	The Turkish Council of Ministers ratified the amending protocol of income tax treaty with Belgium that was signed on 9 July 2013, by way of Decree No. 2016/9214.
Indonesia and Laos	On 29 June 2016, Indonesia ratified the income tax treaty with Laos for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.