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The Netherlands on June 22 announced it has renegotiated tax treaties with Ethiopia, Ghana, Kenya, and Zambia to add antiabuse provisions to the treaties, and said that it hopes to add antiabuse clauses to tax treaties with 23 developing nations. Moreover, talks . . .
Botswana and Ireland, on June 11, signed an agreement to avoid double taxation, according to an report by Star Africa.
Irish Revenue on April 22 released the text of a tax treaty signed by Ireland and Zambia on March 31. The agreement is . . .
The Seychelles Revenue Commission has released a circular that provides guidance to financial institutions subject to FATCA reporting obligations. The guidance describes the information . . .
The South African Revenue Service, on August 14, released a binding private ruling involving the proposed restructuring of a multinational group, concluding that a German Kommanditgesellschaft is a company for South African tax purposes and that the proposed restructuring did not give rise to tax, including capital gains tax. BPR 178
Uganda on November 4 became the 90th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has . . .
The UK and Senegal signed a tax treaty on February 26, the UK’s HM Revenue and Customs has announced. Under the agreement, taxation in the source country on dividends is 5 percent for corporate shareholders that hold at least a 25 percent interest in the company paying the dividends, is 8 percent if the beneficial owner is a pension scheme established in source country, and is 10 percent in other . . .
The UK and Algeria signed a tax treaty on February 18 which provides for maximum rates of withholding tax for interest and royalty payments of 7 percent and 10 percent respectively, UK's HM Revenue and Customs has announced. The treaty also provides for withholding taxes for dividends of 5 percent . . .
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
Irish Tax and Customs has announced that Ireland signed a tax treaty with Ethiopia on November 3. The text of the treaty is not yet available. See, Irish Tax and Customs website.
Hong Kong and South Africa have signed an agreement for the avoidance of double taxation and . . .
The South African Revenue Service has released draft guidance to assist in determining whether an entity has an place of effective management in South Africa so as to be considered a resident of the Republic. The guidance concludes . . .
A tax bill tabled in South Africa's parliament on October 22 proposes taxpayer-favorable changes to Section 23M of the Income Tax Act, which limits interest that can be deducted on loans from a person that is an a "controlling relationship," with the debtor, notes KPMG in an October report. For details, see KPMG.