Switzerland’s Federal Council on April 29 initiated a consultation on a federal decree which would implement automatic exchange of information in tax matters with Australia. The consultation follows up on a joint declaration . . .
Luxembourg and France on Sept. 5 signed the 4th amendment to their 1958 double tax agreement, providing for source country taxation of gains from the sale of shares of companies that primarily invest in immovable property, such as real estate. Text of the amendment (in French), release (in French). For analysis, see Arendt & Medernach, Loyens & Loeff, Baker & McKenzie
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 State of Qatar and the Kyrgyz Republic, on June 1, signed an agreement on the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to income tax. Release
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 . . .
Liechtenstein Prime Minister Adrian Hasler and Italian Finance Minister Pier Carlo Padoan on February 26 signed a tax information exchange agreement (TIEA) based on the OECD model and a protocol and joint declaration on future cooperation in tax matters. The TIEA provides for exchange of information relating . . .
The Switzerland and Italy have reached an agreement in principle to sign a protocol to their double tax treaty to make provision for the OECD standard for the exchange of tax information upon request, the Swiss government announced January 16. The countries have also initialed a roadmap . . .
French Finance Minister Michel Sapin and Swiss Finance Minister Eveline Widmer-Schlumpf, on June . . .
The Chinese government on June 3 announced that China and Indonesia signed a tax treaty protocol that stipulates that the two nations will exempt from VAT aviation enterprises engaged in international transportation with each other. The parties also signed a memorandum of understanding that lists the wholly-owned financial institutions of the two governments which are tax exempt under the treaty. Both agreements were signed on March 26. See, Release.
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 U.K. and Tajikistan signed a double tax treaty on July 1 which generally follows the OECD model tax treaty. The agreement provides for reduced withholding tax rates dividends, interest, and royalties and also includes an exchange of information article and an arbitration provision. For the text, see UK/Tajikistan Double Taxation Agreement (PDF 82K)
The UAE and Denmark on November 3 signed a tax information exchange agreement (TIEA) in Denmark during a UAE delegation tour of Scandinavian . . .
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 . . .
A tax treaty between the United Arab Emirates and Japan signed on May 2, 2013, will enter into force on December 24 , Japan’s Ministry of Finance announced on November 25. The treaty will apply to taxes withheld at source, income taxes, and other taxes beginning January 1, 2014
. . .
Japan’s Ministry of Finance has announced that the “Agreement between the Government of Japan and the Government of the Sultanate of Oman for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”, signed January 9, will enter into force on September 1.
The agreement reduces withholding taxes on dividends to 10 percent . . .
Botswana and Ireland, on June 11, signed an agreement to avoid double taxation, according to an report by Star Africa.
India and Japan have signed a protocol to their 1989 tax treaty, India’s Central Board of Direct . . .
US and Armenian officials will discuss the possibility of entering into negotiations to update their 1973 double tax treaty during the annual US-Armenia Economic Task Force meeting scheduled for . . .
Luxembourg Finance Minister Pierre Gramegna on March 11 signed tax treaties with representatives of Hungary and Uruguay while attending an Ecofin meeting . . .
Hong Kong and the United Arab Emirates on December 11 signed an agreement for the avoidance of double taxation, Hong Kong’s Inland Revenue Department has announced. Under the agreement, tax paid in Hong Kong by UAE residents will be allowed as a credit against tax . . .
The UK’s HM Revenue & Customs, on July 31, released draft implementing agreements and regulations for a common reporting standard for automatic exchange of information, and has requested stakeholder input . . .
Irish Revenue on April 22 released the text of a tax treaty signed by Ireland and Zambia on March 31. The agreement is . . .
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
. . .
Agreements between Switzerland and Jersey, Guernsey, and the Isle of Man regarding the exchange of information on tax matters have entered into force. The agreements . . .
Macau’s Financial Services Bureau on Sept. 26 announced its support for the common reporting standard for automatic exchange of financial account information. Procedures will be initiated to amend Macua’s laws to ensure timely compliance with the new standard, the agency said. Release.
Hong Kong and Korea, on July 8, signed an agreement for the avoidance of double tax and fiscal evasion with respect to taxes on income .
Under the agreement, the Korean withholding tax on interest
. . .
The Australian Government, on May 4, released draft legislation that would give the revised Australia-Swiss tax treaty and accompanying protocol, signed . . .
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
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 . . .
A protocol and exchange of notes between the UK and Japan, signed December 17, 2013, will enter into force on December 12, the UK government announced November 12.The protocol . . .
The UK’s HMRC on January 28 published the text of a tax information exchange agreement (TIEA) signed recently by the UK and Monaco . . .
A tax treaty between the UK and Iceland, signed December 17, 2013, entered into force on November 10, the UK government announced December 15. See, text of UK/Iceland treaty.
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 . . .
China’s State Administration of Taxation has announced that a tax treaty and protocol signed by China and The Netherlands on May 31, 2013, will enter into force on August 31. Press release (Chinese).
Singapore’s agreement with Barbados for the avoidance of double taxation entered into force on 25 April 2014. Release
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