A tax treaty between the Republic of Mauritius and the Republic of Rwanda, signed on 20 April 20, 2013, entered into force on August 4. The provisions of the agreement shall be deemed to apply in Rwanda, in respect of any income year beginning on or after January 1, 2013; and in Mauritius, in respect of any period beginning on or after July 1, 2013. Release
Mauritius was removed from Italy’s tax blacklist with the entry into force of the Italian Stability Law 2015, the Mauritius government announced April 15. The development follows efforts undertaken by Mauritius . . .
The South African Revenue Service on December 15 issued draft rules requiring companies that have consolidated South African turnover of R1 billion and above to keep . . .
India and Mauritius have reached consensus on the conclusion of a tax treaty, the Mauritian government announced July 1. Agreement was reached yesterday following discussions held by a joint working group of Indian and Mauritian officials . . .
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
Mauritius and Austria have signed a tax information exchange agreement (TIEA) according to a release posted on a Mauritius government website March 13. The agreement was . . .
The Swiss Federal Council, on August 20, approved tax information exchange agreements with Andorra, Greenland, San Marino, and the Seychelles. The agreements will be submitted to parliament for approval. press release
The Netherlands, on June 14, ratified a tax treaty signed in 2012 between The Netherlands and Ethiopia, according to a July 15 report by Consultants International. For analysis of the treaty provisions, see Consultants International.
The UK’s HM Revenue and Customs (HMRC) on November 30 announced that it has changed its interpretation of the company residence tie breaker clause in the Jersey-UK tax treaty and in 15 other tax treaties that . . .
Germany had the greatest number of unresolved mutual agreement procedure (MAP) cases among OECD countries during the 2014 reporting period, according to OECD statistics . . .
India’s Punjab and Haryana High Court on August 26 ruled that Blackstone Mauritius and Barclays Mauritius are residents of Mauritius, and thus may take advantage of the India-Mauritius tax treaty, even though the companies’ only tie to Mauritius was . . .
South Africa’s government intends to propose new transfer pricing documentation and reporting rules and to revise controlled foreign company (CFC) rules relating to the digital economy, according to 2015 budget documents released February 25. The proposals will be “in line with” the OECD work . . .
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) have requested stakeholder input on US tax reform, including international tax reform. The goal is to provide input for five bipartisan Finance Committee working groups that . . .
Seychelles has signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters becoming the 85th signatory of the agreement, the OECD announced February 14. The Convention, developed jointly . . .
The Mauritius Revenue Authority on August 28 released a list of frequently asked questions on FATCA . The 2005 deadline for FACTA reporting is August 31. See, Release.
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.
South African Minister of Finance, Mr Nhlanhla Nene, and U.S. Ambassador to South Africa, Mr Patrick H. Gaspard, on June 9, signed an intergovernmental agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA). Release
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