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Tag: #Double taxation

Analysis of exchange of tax information and investment in exchange for citizenship, taking into account the first results of the discussion organized by the OECD

Published: Viacheslav Ivanenko | 24/05/2018 | blog

Back in the first quarter of 2018, namely on February 19, 2018, a draft of advisory document was published on the official website of the Organization for Economic Cooperation and Development (OECD), which called on all interested parties to join the discussion on the OECD strategy for combating the loopholes on using the Common Reporting Standard (CRS, Single standard of tax information exchange) in the “citizenship by the investment” (CBI - granting citizenship in exchange for investments) and “residence by the investment” (RBI - granting a residence permit in exchange for investments). To date, more than 70 jurisdictions in the world offer these schemes. On April 17, 2018, a 96-page document was published on the OECD website (PUBLIC INPUT RECEIVED ON MISUSE OF RESIDENCE BY INVESTMENT SCHEMES TO CIRCUMVENT THE COMMON REPORTING STANDARD), which, in fact, summarized the first results of the discussion and the contents of the official letters to the organization. More than 20 structures were the speakers, including: AFME office in London (Association of Financial Markets in Europe, it brings together the largest agents in the capital markets in the region); ...

UK and Colombia: Agreement about Avoidance of Double Taxation

Published: Sergey Panov | 09/11/2016 | news
The United Kingdom and Colombia

UK and Colombia signed an agreement on avoidance of double taxation November 2, which is designed to support trade and investment by setting the upper limit of income tax on cross-border income. The agreement was signed by the Financial Secretary of the Treasury, Jane Ellison, and Colombian finance minister Mauricio Cárdenas. Income which was received through the international border, potentially exposed to tax in two countries, giving birth to the problem of double taxation. Agreement on avoidance of double taxation ensures that it is fixed, and the income earned in one country is taxed only once, not twice. Eliminating the risk of double taxation will give greater confidence for employees and companies between Britain and Colombia about which taxes they pay and where. The agreement will reduce barriers for international trade and investment, and promote growth and jobs. Also, an agreement of avoidance of double taxation includes provisions to help both countries work together to solve evasion and tax avoidance. The agreement provides that dividends accruing to the pension fund under certain circumstances, dividends will be subject to income tax at a rate of zero percent....

Germany and Costa Rica in order to avoid double taxation on January 1

Published: Sergey Panov | 07/11/2016 | news
Germany and Costa Rica

German Ministry of Finance of 24 October confirmed that the double tax avoidance, the contract between Germany and Costa Rica, will be applied from January 1, 2017. The agreement, which was signed on 13 February 2014, is the first such agreement between Germany and Costa Rica, and contains the OECD standard for the exchange of information between the tax authorities of the two countries. The tax on dividends will generally be limited to 15 percent. However, the rate of five percent would apply if the dividend recipient is a company (other than partners), which directly owns at least 20 percent of the shares of the paying company. Income tax on the interest payments, as a rule, is limited to five per cent. At the same time, the withholding tax on royalties will be capped at 10 percent. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

Japan and Austria have agreed on an international agreement on the avoidance of double taxation

Published: Sergey Panov | 24/10/2016 | news
Japan and Austria

The Government of Japan and Austria have agreed in principle to amend its dual agreement on the avoidance of taxation, in order to further develop trade and investment between the two countries. The new agreement will allow, in accordance with the procedure of mutual agreement, to ensure the settlement of the double tax disputes. Also, the new agreement will reduce the rate of withholding tax at the source of investment income (dividends, interest and royalties), as well as to expand cooperation between the tax authorities of the two countries by providing assistance in collection of taxes. The Organization for Economic Cooperation and Development, in its final report, recommended that countries adopt a binding international agreement on avoidance of double taxation, to the dispute resolution mechanisms have become more efficient. Japan and Austria are among the 20 countries which have declared their commitment to the project. Changes to the Agreement shall enter into force after the completion of the approval process in both countries. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

In Japan double tax go into force

Published: Sergey Panov | 03/10/2016 | news
People of Japan

Protocol double tax agreement tax between Japan and India came into force on 29 September. The Protocol updates the provisions on the exchange of tax information existing contract. It also amends the list of state financial institutions or central banks eligible for exemption from income tax at source of interest payments presentation in Article 11. The revised pact is active in Japan since 1 January 2017, and in India from April 1, 2017. The new double tax agreement with Germany Japan also entered into force on 28 September. The new contract provides for more favorable conditions for companies engaged in trade or investment between the two territories. Agreement again provides tax exemption at source for interest and royalties. Income from dividends will be removed if the company which receives income has a 25 percent share in dividends at least 18 months. Dividend income might otherwise qualify for a reduced rate of five per cent if the company which receives the dividends are held at least five percent of the company paying the dividends for at least six months. Otherwise, it will apply the rate of 15 percent. For updated provisions on the exchange of tax...

Future changes in the Convention between Ukraine and Cyprus on avoidance of double taxation

Published: Sergey Panov | 29/09/2016 | blog
Park in Cyprus

The Ukrainian parliament is currently being finalized for submission to the discussion of the draft law on ratification of the Protocol amending the Convention between the Government of Ukraine and the Government of the Republic of Cyprus for the avoidance of double taxation and prevention of tax evasion on income tax. This Protocol provides for changes in the taxation of dividends, interest on loans, as well as the alienation of the property income. With regard to dividends, the top rate will be reduced from 15 to 10%. But lower tax rate - 5% survive only if ownership of at least 20% of the capital of a legal entity. But how exactly a person - remains a mystery, as in the original text of the Protocol stated "Partnership About", ie the "Partnership", while the bill "Partnership About" translated as "Society". As such, this provision leaves room for corruption because it allows you to abuse the tax authority in determining the rate that must be applied by the payer. The rate of taxation of interest on loans increased from 2% to 5%. Changes are also proposed concerning the taxation of income from the alienation of shares and corporate rights. Unfortunately, due to the...

Ireland drew US attention to changes in the agreement on double taxation

Published: Sergey Panov | 29/08/2016 | news
US double taxation

Department of Finance of Ireland began meeting on the changes in the tax agreement with the United States. The Department explained that the update is seen as necessary in accordance with the decision of the United States to upgrade its model tax treaty. The United States took into account the recommendations on the update within reduce their tax base and shift profits. For example, in 2016, the model does not reduce withholding taxes on payments to highly mobile income - income that taxpayers can easily shift around the globe through deductible payments such as royalties and interest rates - which are made by persons who enjoy low or no tax in respect of income in accordance with the preferential tax regime. In addition, a new article obliges the partners to the extent necessary to make changes to the contract, if the changes cause a doubt one of the partners in the domestic law. Model 2016 also includes measures to reduce the tax benefits of corporate inversions. The update also included the US regulations, which provide that disputes between countries in the application of a double taxation agreement should be resolved through binding arbitration through...

DTA entered into force between Russia and Hong Kong

Published: Sergey Panov | 08/08/2016 | news
DTA entered into force between Russia and Hong Kong

Comprehensive agreement for the avoidance of double taxation (CDTA) was signed in January of this year between Hong Kong and Russia, which came into force on 29 July 2016. According to the sources, this agreement shall remain in force for Hong Kong each year since its signing to double taxation, which took place on or after April 1, 2017. The CDTA is informed about what is required to support efforts to expand the tax obligations undertaken by the two countries in the framework of the «Belt and Road», which is a project of the Chinese government for the economic development aiming at the integration of trade and investment between the approximately 60 countries in Eurasia. In the absence of the CDTA program, of Hong Kong companies income, which conduct their entrepreneurial activities with the help of permanent missions in Russia and taxed in both places if their earnings was received in Hong Kong. On this basis, in the new agreement, double taxation is eliminated, and now any Russian tax paid by the companies on their earnings, will be allowed to tax payable in Hong Kong. Besides, in accordance with this agreement, the rate in Russia on income tax on royalties,...

Ukraine and Malaysia, double tax treaty

Published: Sergey Panov | 29/07/2016 | news
Ukraine - Malaysia

Ukraine need to sign agreement about double tax avoidance with Malaysia what will limit tax rate for dividends, interest, and royalties. According to the deal, the tax rate for dividends will be limited to 15 percent. Special rate for 5 percent will be used for dividends taking from company if it has more than 20 percent of whole company capital paying dividends. Interest and income will depend on maximal tax rate in 10 percent and 8 percent agreeably. The agreement project also include contributions about tax information based on standard developed by the Organisation for Economic Cooperation and Development. The agreement will be signed during official visit of Ukrainian President, Petro Poroshenko, to Malasia 3-5 of August, 2016 year. Ukraine hope to make the same deal with Qatar and other countries and to look through acting agreements with Belgium, Great Britain to the end of 2016 year. Author: Sergey Panovmanaging partner Finance Business...

Singapore and France, double taxation avoidance agreement enters into force

Published: Sergey Panov | 08/06/2016 | news
Singapore and France

Ddouble taxation avoidance agreement between this countries entered into force on June 1,2016 Under this agreement tax withholding capped 15 percent in general and 5 percent where the beneficial owners is a companies owned at least 10 percent from all capital of company. Withholding will arise rate of 10 percent. Then, agreement provides that royalties arising in beneficial company will be taxable only in that country.However royalties had getting like award for using or taking rights for using any copyrights of literary or artistic work, including cinematograph films and tapes for television or broadcasting, or for information concerning commercial experience may be taxed in accordance with the law of the country in which they arise. Treaty also includes provisions to prevent treaty abuse. Also exchange tax information between tax administration of both countries. The new provisions of this agreements will be enter into force from January 1, 2017. Author: Olena Kutova senior lawyer of the Finance Business Service company ...