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Special Reviews

Claiming United States Tax Treaty Benefits

The United States has income tax treaties with 68 foreign countries, under which residents (not necessarily citizens) of foreign countries are taxed at a reduced rate, or are exempt from US income taxes on certain items of income they receive from sources within the United States...Read full report »
BEPS Action 6: OECD Delivers Anti-Treaty Abuse Recommendations

Last week, the Organisation for Economic Cooperation and Developments (OECD) released its first batch of “deliverables” as part of its ambitious plan to limit opportunities for multinational businesses to indulge in base erosion and profit shifting (BEPS) activities to mitigate tax paid...Read full report »
Towards Automatic Exchange of Information Part II

In recent times, exchange of information for tax purposes between governments has largely relied on the text of Article 26 of the OECD Model Tax Convention, which standardises the means by which information...Read full report »
Treaty Shopping

This special feature focuses on the practice of tax treaty “shopping” and what is being done by national tax authorities and the Organisation for Economic Cooperation and Development (OECD) to crack down on this...Read full report »
America’s Stalled Tax Treaties

Double tax avoidance agreements rarely generate controversy. Indeed, dozens of them are approved by legislatures around the world on an almost weekly basis with few people actually noticing. In the United States however...Read full report »

Latest Treaty Updates

Austria - Japan
20/4/2018

Austria's Federal Council on April 5, 2018, approved the DTA with Japan.

India - Kazakhstan
20/4/2018

A protocol updating the DTA between India and Kazakhstan entered into force on March 12, 2018, and was published in India's Official Gazette on April 12, 2018.

Finland - Portugal
20/4/2018

Finland is proposing to terminate its existing DTA with Portugal at the start of 2019, should Portugal fail to ratify a replacement DTA negotiated between the two states.

Spain - Finland
20/4/2018

The Spanish Senate on April 11, 2018, approved a DTA with Finland.

Czech Republic - Kosovo
18/4/2018

The Czech Senate on April 4, 2018, approved a law to ratify the DTA being negotiated with Kosovo.

More Treaty Updates »

Treaty Updates by Territory

Latest News

HMRC To Add To Arsenal Against Diverted Profits

12/4/2018
HM Revenue and Customs has launched a consultation inviting input on proposals to tackle arrangements entered into by individuals, partnerships, or companies that aim to move UK profits outside the scope of UK taxation, typically through the use of offshore trusts and companies.
Read full story »

IRS Explains How To Calculate Transition Tax Liability

12/4/2018
The US Internal Revenue Service and the Department of the Treasury have released comprehensive guidance on how to calculate liability to the Transition Tax, provided for in Section 965 of the Tax Cuts and Jobs Act, and explained elections available to taxpayers.
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Australia Expands Multinational Anti-Avoidance Law

28/3/2018
The Australian Government has introduced legislation to extend the reach of its Multinational Anti-Avoidance Law to cover a range of corporate structures.
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OECD Delivers Rules To Prevent Tax Transparency Standard Evasion

13/3/2018

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Canada To Reform Taxation Of Passive Investments

28/2/2018
Canada's 2018 Budget has provided the long-awaited details of the Government's proposal to limit the tax benefits that can be derived from the holding of passive investments in a private corporation.
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Australia's Board Of Taxation Considers Bare Trusts Tax Reform

14/2/2018
Australia's Board of Taxation has published the results of its review into the taxation of bare trusts.
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Australia To Strengthen Multinational Anti-Avoidance Law

14/2/2018
The Australian Government is to tighten its Multinational Anti-Avoidance Law to prevent the use of certain structures to circumvent the law's application.
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UK Tax Advisers Welcome Inheritance Tax Review

5/2/2018
The Chartered Institute of Taxation has welcomed the announcement that the UK's Office of Tax Simplification is to undertake a review of inheritance tax.
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UK Launches Inheritance Tax Review

1/2/2018
The UK's Office of Tax Simplification has been tasked with investigating options for reform of the UK's inheritance tax.
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HMRC Provides Trust Registration Update

8/1/2018
The UK tax agency, HM Revenue and Customs, has told the Association of Tax Technicians that those not yet able to use its new Trust Registration Service will not yet be penalized, having offered extra time for affected persons to register.
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EU's Tax Info Exchange Rules In Force

5/1/2018
EU tax authorities have gained the right to access data collected by other states under anti-money laundering legislation, following the entry into force of new rules on January 1.
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Australia Consults On Taxation Of Collective Investment Vehicles

21/12/2017
The Australian Government is consulting on a proposed new tax framework for Corporate Collective Investment Vehicles.
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MEPs Approve PANA Committee Tax Recommendations

15/12/2017
Members of the European Parliament have approved the recommendations made by the European Parliament's special committee on tax avoidance and evasion, calling for open registers of beneficial owners, effective protections for whistleblowers, and new rules for intermediaries.
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Luxembourg Announces Beneficial Ownership Register

8/12/2017
The Government of Luxembourg staged a press conference on December 6 to announce the outline of proposals for registries on the beneficial owners of corporate entities and trusts.
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Dutch Government To Tighten Trust Office Rules

21/11/2017
The Government of the Netherlands intends to strengthen the regulatory regime for Dutch trust offices as part of its ongoing efforts to reduce tax avoidance and fraud.
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