Tax Treaties

Morocco publishes mutual agreement procedure guide for resolving tax disputes

August 16, 2021

Nour Ali, DNV, discusses Morocco’s Mutual Agreement Procedure (MAP) guide, released July 5 through the General Tax Administration of the Ministry of Economy and Finance, for resolving tax disputes not in accordance with . . .

Asia-Pacific

Taiwan amends tax treaty rules on residency, permanent establishment, treaty abuse

August 12, 2021

On August 12, Taiwan’s Ministry of Finance promulgated amendments to the regulations governing the application of double tax treaties to update the decade-old rules for developments in international tax trends and conventions, improve administrability, and . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Africa

Switzerland and Ethiopia sign tax treaty

July 30, 2021

The governments of Switzerland and Ethiopia signed a double tax treaty on July 29 in . . .

Asia-Pacific

Singapore–Indonesia updated tax treaty enters into force

July 23, 2021

An updated tax treaty between Singapore and Indonesia entered into force on July 23, replacing . . .

Asia-Pacific

United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses the United Arab Emirates’ July 1 release of mutual agreement procedure (MAP) guidance for resolving tax and transfer pricing disputes through. . .

Asia-Pacific

Japan and Switzerland sign tax treaty protocol

July 16, 2021

Japan and Switzerland on July 16 signed an amending protocol to the tax treaty between the countries that would revise the treatment of taxes on investment income, among . . .

Americas

Japan–Uruguay tax treaty enters into force July 23

June 24, 2021

The tax treaty signed by the governments of Japan and Uruguay on September 13, 2019, will enter into force. . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Europe

Ukraine implements mutual agreement procedure for resolving tax disputes

June 10, 2021

Viktoriia Bublichenko, GOLAW, discusses the Ukraine finance ministry’s March 26 decree establishing the detailed order of conduct of the mutual agreement procedure (MAP) for resolving international tax disputes . . .

Asia-Pacific

Australia, UK agree on how to apply the arbitration provisions added via the MLI to their tax treaty: Australian Taxation Office→

June 2, 2021

Asia-Pacific

MLI’s changes to Singapore-Malaysia tax treaty took effect June 1, government notes: Inland Revenue of Singapore→

June 2, 2021

Africa

Israel, United Arab Emirates sign tax treaty: Reuters→

June 2, 2021

Europe

Russian law denounces tax treaty with Netherlands

May 27, 2021

Russian President Vladimir Putin on May 26 signed a law denouncing the treaty for the avoidance of double taxation between Russia and the Netherlands that was signed in Moscow in 1996 . . .

Featured News

BEPS multilateral tax treaty signatories provide interpretation guidelines

May 20, 2021

Issues relating to the interpretation and implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) should be resolved under several guiding . . .

Americas

Chile clarifies VAT and withholding tax rules for foreign digital services

May 18, 2021

Fernando Barros and Tomás Kovacevic, Barros y Errázuriz Abogados, Santiago, discuss the Chilean tax agency’s April 21 issuance of regulations on the application of value-added tax (VAT) to digitalized services provided from abroad . . .

Asia-Pacific

India sets thresholds for non-resident tax nexus based on economic presence

May 11, 2021

Ritu Shaktawat and Sneh Shah, Khaitan & Co, discuss May 3 Indian government guidance clarifying when a non-resident has a “significant economic presence” in India and is thus deemed to have a taxable presence . . .

Asia-Pacific

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

May 11, 2021

Ritu Shaktawat and Rahul Jain, Khaitan & Co., discuss the High Court of Delhi’s April 22 ruling in a landmark judgment concerning the interpretation of the India-Netherlands tax treaty’s most favored nation clause . . .

Featured News

UN declines to amend model tax treaty on software payment taxation

May 4, 2021

The UN Committee of Experts on International Cooperation in Tax Matters, at its 22nd session, decided against adding a proposal to add computer software payments to the UN model tax treaty’s definition of royalty payments . . .

Europe

Singapore and Serbia sign income tax treaty

May 4, 2021

Singapore and Serbia have signed an income tax treaty, Singapore’s Inland Revenue Authority announced on May 3 . . .

Digital Economy

UN committee considers updates to model tax treaty, developing nation tax guidance

April 21, 2021

The UN Committee of Experts on International Cooperation in Tax Matters has released documents that reveal that significant changes are proposed for the United Nations Model Double Taxation Convention between Developed and Developing Countries and UN guidance addressing . . .

Asia-Pacific

Philippines updates procedures for claiming tax treaty benefits

April 21, 2021

John Regalado & Tanya Beatriz Y. Tan, SyCip Salazar Hernandez & Gatmaitan, discuss the Philippine government’s March 31 memorandum that streamlines the procedures for access to Philippine tax treaty benefits . . .

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

April 14, 2021

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

Europe

Ireland reevaluating tax treaty policy

April 13, 2021

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Multinational

Professor analyzes OECD model treaty changes regarding entitlement to tax treaty benefits for income received through transparent entities: Leopoldo Parada / SSRN→

April 6, 2021

Antigua and Barbuda

Countries continue to permit tax treaty shopping despite BEPS promises

April 6, 2021

Most countries are not fulfilling their commitment to amend their tax treaties to meet global standards aimed at preventing tax avoidance through tax treaty shopping, an April 1 OECD report shows. . .

Asia-Pacific

Synthesized text of the MLI and the Convention Between Australia and the Republic of Indonesia published: Australian Taxation Office→

April 1, 2021

Featured News

Proposed OECD model tax treaty updates cover transfer pricing for interest payments, corresponding adjustments

March 31, 2021

The OECD on March 29 proposed changes to its model tax convention commentary that would alter language regarding the arm’s length treatment of interest payments between associated enterprises located in different countries and clarify a state’s obligation . . .

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance

March 31, 2021

Greece and Hungary have deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), the OECD announced March 30. . .

Americas

Canada’s tax treaty MAP inventory increased in 2019, new report shows

March 22, 2021

The Canada Revenue Agency published on March 8 the annual report on its mutual agreement procedure program for the calendar year 2019, revealing that MAP inventory increased that year. ..

Asia-Pacific

Japan and Ukraine to negotiate new tax treaty

March 19, 2021

The governments of Japan and Ukraine will begin negotiations for a new income tax treaty, replacing the current one, which entered into force in 1986. . .

Featured News

“Platform for Collaboration on Tax” toolkit offers guidance on negotiating tax treaties

March 11, 2021

On March 10, the “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and World Bank Group – launched the final version of its Toolkit on Tax Treaty Negotiations. . .

Americas

Japan, Uruguay sign tax treaty

September 18, 2019

The governments of Japan and Uruguay on September 13 signed their . . .

Americas

US announces entry into force dates for new tax treaty protocols with Japan and Spain

September 3, 2019

The US Treasury has announced that a protocol to the US-Japan tax treaty entered . . .

Africa

Kenya, Turkey to sign tax treaty: Xinhua→

July 17, 2019

Armenia

Singapore, Armenia sign tax treaty

July 8, 2019

Vietnam’s Ministry of Finance today announced . . .

Africa

Japan, Nigeria to begin tax treaty negotiations

June 18, 2019

The Ministry of Foreign Affairs of Japan . . .

Americas

Japan, Argentina sign tax treaty

June 30, 2019

Japan’s Ministry of Finance on June 27 announced . . .

Europe

Switzerland and Netherlands sign protocol amending tax treaty

June 12, 2019

Switzerland and the Netherlands have signed a protocol of amending their tax treaty . . .

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Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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