Africa
Russia, Malta, Mauritius, Hungary, Gabon, Indonesia, Lithuania sign tax agreement on exchange of country-by-country reports
In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . .
Singapore-South Africa tax treaty enters into force
A new Singapore-South Africa tax treaty entered into force on December 16, Singapore’s Ministry of Finance . . .
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Singapore and Ethiopia sign tax treaty, text available
Singapore and Ethiopia signed a tax treaty on August 24, Singapore’s Inland . . .
Portugal must grant company at least partial tax deduction for dividends received from Tunisian or Lebanese subsidiaries, EU court rules
Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .
Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance
Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .
New protocol allows India to tax capital gains from sales by Mauritius residents of Indian company stock
India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .
UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.
Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method
Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .
Ireland initials tax treaty with Oman, treaties with Botswana, Ethiopia enter into effect
Ireland has concluded negotiations for a new tax treaty with Oman and expects the treaty to be signed shortly, Irish Revenue . . .
Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance
Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .
Bermuda, Kazakhstan, Côte d’Ivoire join BEPS group fighting cross-border tax avoidance
Bermuda, Kazakhstan, and Côte d’Ivoire have joined the “Inclusive Framework on BEPS,” to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . .
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
UK requires companies in Caymans, BVI, other territories, to publicly disclose ownership
Britain’s overseas territories, including the tax havens of Cayman Islands, British Virgin Islands, and Bermuda, must introduce publicly accessible registers of the beneficial ownership of companies located in their jurisdictions before 2021 or the UK will require them to do so, a law approved by UK Parliament . . .
South African tax bill amends hybrid instrument rules, eliminates planned withholding on service fees
Peter Dachs of ENSafrica, Cape Town, discusses proposed revisions to South Africa’s tax law, released 8 July, that would reverse the planned introduction of withholding tax on service fees and that would modify the tax treatment of hybrid debt, share incentive schemes, and trusts that provide interest-free loans . . .
Senegal signs multilateral agreements to fight tax avoidance and evasion
Senegal on February 4 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 93rd jurisdiction to sign the document, and the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country . . .