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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

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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MAP Peer Reviews Released For UK, US, Others

2/10/2017
The OECD has released its first peer review reports of mutual agreement procedure frameworks in Belgium, Canada, the Netherlands, Switzerland, the UK, and the US.
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Mauritius Denies Plans To Renegotiate DTA With India

8/9/2017
Mauritius's Ministry of Finance has denied that there are plans for a renegotiation of the jurisdiction's double tax agreement with India in the near future.
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Liechtenstein Approves Tax Treaty With Monaco

4/9/2017
Liechtenstein's Government has approved a double taxation agreement with Monaco, according to an announcement on the principality's website.
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Switzerland, Zambia Sign DTA

30/8/2017
Switzerland and Zambia have signed a new double taxation agreement which sets maximum withholding tax rates for dividends and interest.
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Saudi Arabia And Hong Kong Sign DTA

25/8/2017
Hong Kong and Saudi Arabia have signed a comprehensive agreement for the avoidance of double taxation.
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Croatia, New Zealand Eye Double Tax Avoidance Deal

22/8/2017
Croatia and New Zealand have agreed that they should negotiate an agreement on the avoidance of double taxation.
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New Zealand Moving Forward With Tax Treaty Amendments

9/8/2017
The New Zealand Government has announced the signature of two Orders of Council that will implement amendments to its tax treaty arrangements with India and San Marino.
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NZ Tables BEPS Multilateral Convention Law

8/8/2017
The New Zealand Government has tabled in parliament a multilateral convention that will enable it to update tax treaties in line with the OECD's recommendations on base erosion and profit shifting.
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Switzerland, Belgium To Begin Exchanging Tax Info

8/8/2017
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force.
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BEPS Toolkit Released On Offshore Indirect Transfers

7/8/2017
The Platform for Collaboration on Tax, a joint initiative of the OECD, the International Monetary Fund, the United Nations, and the World Bank Group, has launched for consultation a draft toolkit designed to help developing countries address concerns surrounding the tax treatment of offshore indirect transfers of assets.
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Switzerland, Ecuador Sign DTA Protocol

3/8/2017
Switzerland and Ecuador have signed a protocol to their double taxation agreement that will introduce new provisions for the exchange of information.
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Cameroon Signs BEPS Multilateral Instrument

12/7/2017
On July 11, 2017, Cameroon's Finance Minister, Alamine Ousmane Mey, signed the OECD's Multilateral Instrument, designed to prevent the avoidance of tax through the abuse of double tax avoidance treaties.
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Switzerland, Latvia Revise Tax Treaty To Tackle BEPS

30/6/2017
On June 28, 2017, the Swiss Federal Council adopted the dispatch on a revised double taxation agreement with Latvia and submitted it to Parliament for approval.
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Countries Urged To Sign Up To Mandatory Binding Arbitration

19/6/2017
The International Chamber of Commerce has stressed the need for more countries to adopt mandatory binding arbitration to better resolve double tax disputes.
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