Europe
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Europe
Asia-Pacific
Americas
Cayman Islands financial institutions to face new CRS reporting thresholds, self-cert requirements
Denise Hintzke and Douglas Scott of Deloitte Tax LLP discuss recent, significant changes made to the Cayman Islands common reporting standard (CRS) regime for financial institutions, including an expansion of the pool of persons subject to Cayman CRS reporting and a new process for entity self-certification . . .
Africa
Americas
Swiss advance information exchange for tax purposes with Singapore, Hong Kong, other financial centres
Davide Anghileri of the University of Lausanne discusses the Swiss government’s progress advancing exchange of financial account information for tax purposes with Singapore, Hong Kong, and several countries, including Bahamas and Bahrain, that apply automatic exchange in a non-reciprocal manner . . .
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Americas
Europe
Americas
Americas
Asia-Pacific
Asia-Pacific
China introduces Circular 88, offering new dividend withholding tax exemption to encourage foreign investment
David Dingfa Liu, a partner with FuJae Partners, Shanghai, discusses Circular 88, a tax incentive introduced by the Chinese government on December 21 that allows multinationals to defer withholding tax which would otherwise be imposed on dividends distributed to foreign investors when the dividends are reinvested in China. . . .
Americas
Europe
Europe
Asia-Pacific
India to accept transfer pricing APA, MAP applications even if corresponding adjustment treaty provision absent
The Indian government today clarified that it will accept transfer pricing mutual agreement procedure (MAP) cases and bilateral advance pricing agreement applications in situations where the applicable tax treaty does not include a provision comparable to Article 9(2) of OECD Model Tax Commentary, providing for corresponding adjustments. A Central . . .
Americas
Multinational
Europe
Multinational
Asia-Pacific
Americas
Europe
Europe
Africa
Americas
Asia-Pacific
High Court rules India can’t tax Dutch company’s sale of shares in Indian company that holds Indian immovable property
Joachim Saldanha and Ashish Sodhani of Nishith Desai Associates discuss a recent Indian High Court decision which concludes that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company are not taxable in India under the India-Netherlands tax treaty . . .
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Multinational
Belgium
Asia-Pacific
Asia-Pacific
Europe
France’s withholding tax on dividends paid to EU subsidiaries violates EU law, Commission says
The EU Commission today notified France that it considers France’s withholding tax on dividends paid to subsidiaries located in other EU States or European Economic Area (EEA) Members States to be contrary EU law. The Commission said . . .
Asia-Pacific
UAE signs multilateral treaty to fight offshore tax evasion and multinational corporation avoidance
The United Arab Emirates on April 21 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 109th jurisdiction to participate in the convention. The treaty, developed in 1988 by the OECD and the Council of Europe, would enable . . .
Europe
EU court to review German law denying withholding tax exemption for some dividends paid to foreign parents
The European Court of Justice has published a reference for a preliminary ruling in a case challenging a German law that denies relief from withholding tax on some distributions . . .
Asia-Pacific
Europe
New Germany-Switzerland tax arbitration agreement provides legal certainty
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
Denmark
EU court to consider beneficial ownership definition for interest and royalty directive
The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .
