#Double taxation Archives - Page 2 of 3 - Law firm Finance Business Service: offshore registration, tax planning, legal services

DTA entered into force between Russia and Hong Kong

Published: Sergey Panov | 08.08.2016 |

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, up to the...

Ukraine and Malaysia, double tax treaty

Published: Sergey Panov | 29.07.2016 |

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 |

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 ...

Singapore-Cambodia, an agreement on the double taxation avoidance

Published: Sergey Panov | 25.05.2016 |

Singapore and Cambodia signed an agreement on avoidance of double taxation with a view to increasing cross-border trade and investment between the two countries. The agreement clarifies the rights in relation to tax in both countries on all forms of income streams arising from cross-border business activity but also ensures that the income will not be taxed twice. Under the deal tax on dividends, interest and royalties will depend on the maximum rate of 10 percent. Some of the interest payment would be released. The agreement also includes provisions for the resolution of contractual disputes through the process of mutual agreement and provides for the exchange of information in tax matters. The Treaty will enter into force after the completion of the domestic ratification procedures in both countries. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

Tax breaks in Hong Kong’s double tax agreements

Published: Sergey Panov | 24.05.2016 | news

Recently Hong Kong has signed DTA with Romania and Russia, which will cut tax for cross-border trade and investors. Due to Romanian double tax agreement, income tax of Romania can be paid from any other tax which has the same income. Withholding of tax in Romania will cut to current 16 percent to 5 or even 3 percent. The income profit earned by Hong Kong's residents will be enjoying to for full tax exemption. Due to Russian DTA from Hong Kong will income tax paid by Russian residents or companies shall be allowed as a credit against any tax payable in respect of the same income in Russia. Withholding of tax in Russia will cut from current 20 percent or 30 to even 3 percent. The cap of 5 percent will be allowed if even one of the official owner has more than 15 percent of common profit of the company. Profit from international shipping transport also will be enjoying to for full tax exemption. Hong Kong airlines which operating in Russia will pay tax only due to Hong Kong's tax rate. Author: Sergey Panovmanaging partner Finance Business...

US corporate tax reform

Published: Sergey Panov | 23.05.2016 | news

Chairman of the Senate Finance Committee Orrin Hatch held a hearing on the question of integrating the new corporate tax reform. The reforms will allow US corporations to deduct dividends paid from their tax calculations. Hatch said that "under the current system the income obtained only once on behalf of the shareholders is taxed twice because of fiction created by the law which considers the business and its owners as two separate taxpayers. In particular, the income is taxed at a rate of 35 percent. " Hatch is also noted that "the current system of double taxation has led to a number of unpredictable economic distortions which might not exist in a more integrated system" - including the bias in the selection of a business entity in relation to the corporate model. There are two main ways to integrate corporate and individual tax code to allow shareholders for the corporate tax credit or allow corporations to deduct dividends. One of the reasons why Hatch chose to follow the latter option is that it will allow companies to reduce their own effective tax rates. It is also necessary to establish the relationship between debt and equity which may help with certain...

Hong Kong – Latvia, the avoidance of double taxation agreement

Published: Sergey Panov | 18.04.2016 |

It has been signed an agreement on avoidance of double taxation between Hong Kong and Latvia on 13 April, Riga. This is the 35th contract that Hong Kong has signed with its trading partners. The Treaty establishes a clear allocation of taxation rights between the two jurisdictions and it helps investors better assess their potential tax liabilities. It has been signed an agreement on avoidance of double taxation between Hong Kong and Latvia on 13 April, Riga. This is the 35th contract that Hong Kong has signed with its trading partners. The Treaty establishes a clear allocation of taxation rights between the two jurisdictions and it helps investors better assess their potential tax liabilities. In the absence of an agreement on avoidance of double taxation the profits of Hong Kong companies which operate through a permanent establishment in Latvia, were taxed in both places if the income comes in Hong Kong. Similarly, revenues received Latvian residents in Hong Kong are subject to tax in Latvia. Under the new agreement, the tax rate in Latvia for royalty (currently different rates to 23 per cent in some cases) will be reduced to zero percent for companies and a maximum of...

The agreement on the avoidance of double taxation changes, Ukraine – Cyprus

Published: Sergey Panov | 06.04.2016 |

The Ukrainian government has announced a change to the existing agreements on avoidance of double taxation signed with Cyprus. The revised text will close a loophole that led to the fact that the income from immovable property situated in Ukraine avoid taxation in Ukraine. Income derived by a Cyprus resident from the sale of shares or other corporate rights will be subject to taxation in Ukraine if more than 50 percent of this revenue is directly or indirectly related to income immovable property situated on the territory of Ukraine. The minimum rate on dividends is increased from two percent to five percent. This low rate is used when the recipient owns 20 or more percent of the company distributing dividends and investment at least EUR 100,000 to obtain holding. The tax rate of ten percent is used otherwise. The revised section on dividends will come into effect not earlier than 1 January 2019. Other changes proposed to bring in agreement with the latest international tax standards developed by the Organization for Economic Cooperation and Development. The amendment has been sent to the Ukrainian legislators for approval. Author: Sergey Panovmanaging partner Finance...

The avoidance of double taxation agreement, UAE – Ecuador

Published: Sergey Panov | 31.03.2016 |

Representatives of the United Arab Emirates and Venezuela met at the end of March 2016, to discuss ways to strengthen economic and trade ties between the two countries. During the meeting, Obaid Humaid Al Tayer, UAE Minister of Finance emphasized the UAE's efforts to strengthen relations with various countries around the world and for the implementation of laws that support trade and investment and stimulate economic diversification. He noted that UAE is continuing its efforts to provide key benefits for both the public and private sectors, through the execution of agreements for the avoidance of double taxation, joint tax laws, as well as agreements to prevent tax evasion on income tax, which increases the economic growth and investment between the two countries. UAE and Ecuador in Quito signed an agreement on avoidance of double taxation on income dated September 1, 2012. Both sides stressed the importance of implementing the agreement. The total foreign trade between the two countries in the first nine months of 2015 amounted to only 40.3 million dollars, according to the UAE Ministry of Finance. Author: Olena Kutova senior lawyer of the Finance Business...

Singapore – the United Arab Emirates, Tax improvement agreement

Published: Sergey Panov | 22.03.2016 |

The second protocol to the double tax agreement between Singapore and the United Arab Emirates, entered into force on 16 March 2016 and will be effective from January 1, 2017, reducing tax rates and changing the rules of the permanent establishment (PE). The protocol, which was signed in October 2014, revises the conditions for the inclusion of longer periods of thresholds for determining the existence of a permanent establishment. For example, the report claims that the PE occurs where there is a building site; construction, assembly or installation project; or supervisory activities in connection with this lasts for more than twelve months, in contrast to the threshold of nine months. In addition, under the revised protocol, provision of services, including consultancy services, will be a PE if such activities continued throughout the aggregation of 300 days in any period of twelve months, compared to six months. The agreement also upgrades the position of the exchange of tax information. The protocol removes withholding tax on interest at source, provided that the interest income may be taxed only in the country of the recipient. Provisions establishing five percent tax...

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