Asia-Pacific
Australia announces intent to begin tax treaty negotiations with Israel
Australia’s Treasurer Joe Hockey on September 17 announced that Australia intends to commence tax treaty negotiations . . .
Treaties
Europe
UK and Kosovo sign tax treaty
The UK and Kosovo on June 4 signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. See:, Treaty.
Asia-Pacific
UAE and Luxembourg sign protocol to amend tax treaty
UAE and Luxembourg on October 26 signed a protocol to amend the countries’ 2005 agreement on the avoidance of double taxation and prevention of fiscal evasion on income and capital. Release.
Asia-Pacific
Hong Kong signs TIEAs with Denmark, the Faroes, Greenland, Iceland, Norway, and Sweden
Hong Kong signed tax information exchange agreements with six jurisdictions on August 22: Denmark, the Faroe Islands, Greenland, Iceland, Norway, and Sweden, according to . . .
Africa
Singapore and Seychelles sign double tax agreement, full text available
Government representatives of Singapore and Seychelles, on July 9, signed an Agreement for the Avoidance of Double Taxation in New York. Under the agreement, the withholding tax on dividends is reduced to 12 percent and the withholding tax on royalties is reduced to eight percent. The agreement also provides for the exchange of tax information. Agreement, Press release.
Europe
Russia and Malta ratify double tax treaty
Russia and Malta have ratified a double tax treaty signed on April 24. For analysis of the treaty, see Boston Trust Company Isle of Man, EMCS,
Asia-Pacific
Singapore and Russia revise tax agreement, text available
Singapore and Russia have signed a protocol amending to their tax treaty . . .
Europe
Spain, Guernsey sign tax information exchange agreement
Guernsey and Spain on November 10 signed an agreement on exchange of information . . .
Africa
Switzerland’s TIEAs with Andorra, Greenland, San Marino, Seychelles enter into force
Tax information exchange agreements (TIEAs) between Switzerland and Andorra, Greenland, San Marino, and the Seychelles have been ratified and came into force in July and August, Switzerland’s Federal Department of Finance announced on September 9. All the . . .
Asia-Pacific
Revised Singapore-Thailand tax treaty lowers withholding tax rates
ngapore and Thailand signed a new tax treaty June 11, agreeing to lower the withholding tax rates . . .
Asia-Pacific
Protocol enhancing Hong Kong/Vietnam information exchange enters in force
The second protocol to the agreement between Hong Kong and Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income has entered into force, Hong Kong’s Inland Revue Department (IRD) announced February 23. The protocol came into . . .
Asia-Pacific
Singapore-Liechtenstein tax treaty enters into force, text available
An agreement for the avoidance of double taxation between Singapore and Liechtenstein, signed June 27, entered into force on July 25. The treaty provides for exchange of tax information on request, and lowers withholding taxes on dividends to zero, on interest to 12 percent, and on royalties to eight percent. Treaty
Asia-Pacific
China announces signing of tax arrangement with Taiwan
China’s State Administration of Taxation on November 3 announced the August 25 signing of a tax arrangement between China and Taiwan . . .
Asia-Pacific
Asia-Pacific
Japan and Hong Kong exchange notes on information exchange
Japan and Hong Kong on December 10 exchanged notes confirming the understanding that information concerning additional taxes will be exchanged, Japan’s Ministry of Finance has announced. The additional taxes are the Japanese inheritance tax, gift tax, consumption tax; and any similar taxes later imposed. See, Japan Ministry of Finance release.
Europe
Swiss proposal would unilaterally apply OECD information exchange standards to treaties
The Swiss Federal Counsel on October 22 launched a consultation on a proposed law that would . . .
Europe
Switzerland and Iceland sign double tax agreement
Switzerland and Iceland, on July 10, signed a double taxation agreement which includes exchange of information provisions and an arbitration clause. The agreement replaces a 1988 double tax agreement. Under the new agreement, royalties are subject to no more than 5 percent tax in the source state. The parties agreed to a withholding tax exemption for divided payments from significant holdings of at least 10 percent and for divided payments to pension funds and national banks. The agreement specifies that pension contributions in the other country are deductible. For more details, see press release.
Asia-Pacific
Japan and Qatar to begin tax treaty negotiations
Japan’s Ministry of Finance announced on December 5 that it will begin negotiations with Qatar for a tax agreement between the counties. The first round of negotiations will begin December 8, in Tokyo. Release.
Asia-Pacific
Japan-Sweden protocol to enter into force October 12
The requirements for the entry into force of the protocol between Japan and Sweden, signed December 5, 2013, were met on Sept. 16 and the treaty will enter into force on October 12, Japan’s Ministry of Finance has announced.
The protocol sets a zero rate of withholding on interest and royalties. The withholding rate for dividends is zero for corporate shareholders that hold at least 10 percent voting power, and is 10 percent in other cases.
The protocol also adds measures to prevent abuse of the treaty, introduces an arbitration proceeding to the mutual agreement procedure, and expands exchange of information. Release, Protocol (66KB).
Africa
Rwanda-Mauritius treaty enters into force
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
Asia-Pacific
Switzerland and Uzbekistan sign protocol to update exchange of tax information
Switzerland and Uzbekistan, on July 1, signed a protocol to amend their double taxation agreement. The protocol brings the administrative assistance clause into line with the applicable international standard for the exchange of information upon request. The protocol must be ratified by both countries before it can enter into force. Release
Americas
Americas
China signs tax treaty with Chile, protocol with Russia
China has signed a tax treaty with Chile and a protocol to its tax treaty with Russia, China’s State Administration of Taxation said in July 3 English-language releases. The treaty with Chile, signed May 25, is is the 100th treaty signed by China, the government . . .
Europe
Switzerland and Liechtenstein reach agreement on double tax treaty
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
Asia-Pacific
TIEA between Isle of Man and Indonesia enters into force
The Isle of Man Treasury announced on October 21 that the “Agreement for the Exchange of Information Relating to Tax Matters” signed by the Isle of Mann and Indonesia on June 22, 2011, entered into force on September 22. Release.
Africa
India and Mauritius reach agreement on tax treaty
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 . . .
Africa
Mauritius and Austria sign TIEA
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 . . .
Asia-Pacific
Liechtenstein and United Arab Emirates set to sign tax treaty
Liechtenstein and United Arab Emirates have initialed a tax treaty, Liechtenstein’s Ministry for General Government Affairs announced March 4. The treaty largely follows the OECD Model Convention and provides for cooperation on tax matters between the tax authorities. The agreement also clarifies the tax treatment of asset structures . . .
Asia-Pacific
Japan and Qatar sign tax treaty
Japan and Qatar on February 20 signed a tax treaty in Tokyo, the Japanese Ministry of Finance has announced. Under the agreement, taxation in the source country on dividends is reduced to 5 percent for corporate shareholders that hold at least a 10 percent interest, and is 10 percent in other cases. Taxation . . .
Estonia
Switzerland and Estonia sign protocol to amend double taxation agreement
Switzerland and Estonia, on August 25, signed a protocol to amend their double taxation agreement.
Under the agreement, interest and royalty payments are exempt from withholding tax. Dividends are also exempt from withholding tax if the company receiving the dividend holds a stake of at least 10 percent in the capital of the distributing company for at least one year. In other cases, the withholding tax rate for dividend distributions is 10 percent.
The agreement also provides for the exchange of information upon request in accordance with the currently applicable international standard.
The agreement must be approved by parliament in both countries before it can come into force. Release
Africa
Swiss Federal Council approves TIEAs with Andorra, Greenland, San Marino and the Seychelles
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
Asia-Pacific
India and South Korea agree to suspend tax collection while MAP pending, new treaty to govern transfer pricing disputes
India and South Korea have signed a memorandum of understanding (MoU) agreeing to suspend the collection of taxes while mutual agreement procedure . . .
Americas
Japan and Chile agree to terms of tax treaty
Japan and Chile have agreed in principle on a tax treaty, Japan’s Ministry of Finance announced . . .
Asia-Pacific
Hong Kong/Italy tax treaty published
Hong Kong’s Inland Revenue Department has released the text of a tax treaty signed with Italy on January 14, 2013 . . .
Americas
UK guidance implements automatic exchange of information
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
Americas
New Zealand discloses plans for 2015 tax treaty negotiations
New Zealand expects in 2015 to negotiate tax treaties or protocols with Korea, Australia, Norway, Slovak Republic, China . . .
Cyprus
Ukraine and Cyprus sign protocol to tax treaty adding most favored nation clause
The government of Cyprus on December 11 announced that it has signed a protocol . . .
Asia-Pacific
UAE and Norway sign agreement on exchange of information for tax purposes, consider tax treaty
UAE and Norway officials signed an agreement on exchange of information for tax purposes during . . .
Cyprus
Cyprus, Ukraine conclude tax treaty protocol
Cyprus’s Ministry of Finance announced September 8 that it has agreed with the government of Ukraine to conclude a protocol to the countries’ November 2012. . .
