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Special Features

Claiming United States Tax Treaty Benefits

TreatyPro.com Editorial
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...
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BEPS Action 6: OECD Delivers Anti-Treaty Abuse Recommendations

TreatyPro.com Editorial
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...
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Towards Automatic Exchange of Information Part II

By TreatyPro Editorial
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...
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Treaty Shopping

By TreatyPro Editorial
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...
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America’s Stalled Tax Treaties

By TreatyPro Editorial
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...
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Focus On BEPS Action 6: Prevention of Tax Treaty Abuse

TreatyPro.com Editorial
On March 14, 2014, the Organisation for Economic Cooperation and Development (OECD) published its Discussion Draft on Action 6 of the Base Erosion and Profit Shifting (BEPS) project, on preventing treaty abuse. However, as with many other aspects of the OECD’s work in relation to BEPS, respondents have warned that the proposals threaten to punish innocent taxpayers and disrupt global investment flows.
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Canada-US DTA: FATCA Provisions Added

By TreatyPro Editorial
On February 5, 2014, Canadian Finance Minister Jim Flaherty and National Revenue Minister Kerry-Lynne D. Findlay announced that, after lengthy negotiations, Canada and the United States had signed an intergovernmental agreement (IGA) under the longstanding Canada-US Tax Convention to implement enhanced information reporting between the two countries required by the US Foreign Account Tax Compliance Act (FATCA)
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Hong Kong’s Expanding Tax Treaty Network

By TreatyPro Editorial
Unusually for a major global business and financial centre, Hong Kong has only a limited network of double tax avoidance agreements, and until quite recently, had no comprehensive tax treaties in force at all. But as the global tax landscape shifts, and pressure increases on low-tax and offshore territories to become more transparent, the situation is beginning to change, as this special feature shows.
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The Impact Of BEPS On Double Tax Treaties

By TreatyPro Editorial
The corporate world has generally accepted that taxation rules have fallen far behind the fast-evolving world of international business practice, and that the BEPS project provides a basis for a discussion between taxpayers and governments on how things can change for the better for both parties.
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Towards Global Automatic Exchange of Information?

By TreatyPro Editorial
This feature explores the various plurilateral efforts underway to achieve more standardization in the exchange of information (EoI) for tax purposes between national revenue authorities, including the European Union (EU) Savings Tax Directive, the United States Foreign Account Tax Compliance Act (FATCA) and the Organisation for Economic Cooperation and Development’s (OECD’s) lesser known tax treaty TRACE project.
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The India-Mauritius DTA Saga

By TreatyPro Editorial
They’ve tried a number of times over the past decade or more, but the Indian government has failed every time to force the changes it wants to the India/Mauritius tax treaty to stop foreign investors from avoiding Indian taxes. With the two governments once again discussing this issue, this article examines the history of the dispute, and the possibilities for change.
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The Evolving State of the OECD Model Tax Convention

By TreatyPro Editorial
In this article, we take a look at the Organisation for Economic Cooperation and Development’s (OECD) ongoing efforts to reform certain aspects of the Model Tax Convention, particularly with respect to recent proposals on changes to the ‘beneficial ownership’ and ‘permanent establishment’ articles, and tax treaty treatment of emissions permits.
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Switzerland's Treaties in the Transparent New World

By TreatyPro Editorial
In this feature, we look at how Switzerland is gradually falling into line with internationally-agreed standards on tax transparency by modifying its extensive network of bilateral tax treaties and underlying legislative framework, and committing to specific information exchange arrangements.
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Focus on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters

By: The Treaty Pro Team
We’ve seen how, increasingly, double tax avoidance agreements have been negotiated to contain standard wording on the exchange of information for tax purposes, and tax information exchange agreements between offshore jurisdictions and major countries have mushroomed in the past two years; but governments also have another weapon in their armoury to combat international tax evasion – the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
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Latest News

New Finland-Spain Tax Treaty Effective 2019

23/5/2018
A new tax treaty between Finland and Spain, which will broaden the Finnish Government's taxing rights with respect to pension income, will be effective from 2019, according to the Finnish Ministry of Finance.
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Malta Ratifies BEPS Convention

3/5/2018
Malta has become the latest country to ratify the OECD's multilateral convention to counter base erosion and profit shifting.
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Switzerland Adopts Dispatch On New DTAs

19/4/2018
The Swiss Federal Council has adopted dispatches on a new double tax agreement with Zambia and a protocol to the current agreement with Ecuador.
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Finnish Lawmakers Call For Termination Of Portuguese DTA

13/4/2018
The Finnish Government has proposed that parliament terminate the 1970 double tax agreement between Finland and Portugal so that Finland can tax the pensions of retired Finnish expats.
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India Adds BEPS Provisions To Qatar Tax Treaty

29/3/2018
India has approved amendments to its double tax agreement with Qatar.
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France, Luxembourg Sign New Tax Treaty

22/3/2018
A new tax treaty incorporating the latest international tax standards was signed by France and Luxembourg on March 20.
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Sweden To Legislate To Adopt BEPS Treaty Changes

22/3/2018
The Swedish Government has approved a bill to ratify the BEPS Multilateral Instrument and has submitted it to parliament.
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India, Hong Kong Sign Double Tax Deal

20/3/2018
Hong Kong and India on March 19 signed an agreement to avoid double taxation and limit withholding tax rates on passive income at source.
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US And Liechtenstein To Negotiate Double Tax Treaty

16/3/2018
The governments of Liechtenstein and the United States have recently discussed the possibility of beginning negotiations for a bilateral double tax avoidance treaty.
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Luxembourg Says EU's Digital Tax Must Be Lawful

13/3/2018
Luxembourg Finance Minister Pierre Gramegna has said that any special tax measures against large digital companies should respect European Union law.
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Barbados, Australia Eyeing Double Tax Pact

7/2/2018
Barbados's Minister of Foreign Affairs and Foreign Trade, Maxine McClean, has stressed the importance of tax cooperation with Australia in recent comments at a reception marking Australia Day.
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Netherlands Confirms Tax Treaty Negotiation Priorities

31/1/2018
The Netherlands will seek to resume discussions towards double taxation avoidance treaties with several countries in 2018, including the United States, the Government has said.
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Barbados Commits To Amend Tax Treaties To Block BEPS

26/1/2018
Barbados has become one of the latest jurisdictions to sign the BEPS multilateral instrument to incorporate provisions within its tax treaties to counter base erosion and profit shifting.
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Greece Raises BEPS Concerns With Bulgaria

25/1/2018
The heads of the Greek and Bulgarian tax authorities have met to discuss ways in which bilateral cooperation can be boosted with a view to reducing levels of tax avoidance and evasion, particularly with respect to Greek companies shifting profits to Bulgaria.
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Japan, Iceland Sign Double Tax Agreement

16/1/2018
Japan's Ministry of Finance has reported the signing of a double tax agreement with Iceland in Reykjavik.
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Cyprus, Saudi Arabia Negotiate Double Tax Agreement

4/1/2018
Cyprus's Ministry of Finance says the island has signed a double tax agreement with Saudi Arabia with respect to taxes on income and for the prevention of tax evasion.
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Curacao Signs BEPS Multilateral Instrument

2/1/2018
Curacao, the low-tax Caribbean territory, has become the latest jurisdiction to sign the BEPS multilateral instrument to revise tax treaties to counter base erosion and profit shifting.
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Jersey Ratifies BEPS Multilateral Instrument

26/12/2017
Jersey has become one of only three jurisdictions to ratify the BEPS multilateral instrument to revise tax treaties to counter base erosion and profit shifting.
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Swiss Gov't Agrees Double Tax Avoidance Deal With Kosovo

16/11/2017
The Swiss Federal Council has adopted a dispatch on the implementation of a new double tax agreement with Kosovo.
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UK Reiterates 'Unwavering Support' for Gibraltar

6/11/2017
The UK's Economic Secretary to the Treasury, Stephen Barclay, said the UK's support for Gibraltar is "unwavering," in a recent address to mark Gibraltar Day.
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Switzerland Adopts Dispatch On Pakistan DTA

26/10/2017
The Swiss Federal Council has adopted a dispatch on the implementation of a new double taxation agreement with Pakistan.
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OECD's Action 5 BEPS Work Producing 'Tangible Results'

18/10/2017
Countries have made substantial progress in ensuring that their preferential tax regimes do not give rise to base erosion and profit shifting issues, according to the OECD's new peer review report under Action 5 of the BEPS Action Plan.
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New Japan-Denmark DTA To Waive Cross-Border Tax

16/10/2017
The Japanese and Danish governments announced on October 11 that they had signed a new agreement for the avoidance of double taxation in Tokyo.
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Canada Praised After BEPS Minimum Standard Peer Review

6/10/2017
Canada is largely compliant with the BEPS minimum standard on improving tax dispute resolution, one of the first ever OECD peer reviews has found, but it needs to make a number of changes to be regarded fully compliant.
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Japan's NTA Releases Guidance On MAP Article

6/10/2017
Japan's National Tax Agency has released guidance on the mutual agreement procedure article found in many of Japan's double tax treaties.
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