Egyptian telecom company, Orascom Telecom, has announced that its Algerian subsidiary, Orascom Telecom Algérie (OTA), has received a rejection to its appeal, made in December last year, against the notice for taxes and penalties it had received from the Algerian tax authorities the month previously.
The notice, amounting to DZD43.9bn (USD615m), was levied in respect of the 2005, 2006 and 2007 tax years. Although OTA has said that its accounts were fully audited during those years, the Algerian tax department increased OTA’s income and non-deductible expenses, resulting in a 45% increase in taxable profits. OTA also argued that, during the period in question, it had the benefit of tax exemptions and protections granted under an investment agreement.
Pending the hearing of the appeal, OTA was not required to pay the full amount of the tax notice. In order to file its appeal, however, OTA had to pay 20% of the reassessment, which is recoverable if OTA's appeal is ultimately successful.
If OTA now wishes to continue through the appeal process, either before the Central Commission or the State Counsel, it will be required to pay another 20% of the remaining balance of the alleged taxes and penalties from its own resources. The amount paid will again be recoverable if OTA is successful in its appeal.
In a statement, it was confirmed that OTA does indeed intend to pursue the Algerian appeal system, and will soon pay over the required amount. On the other hand, its parent company, Orascom Telecom, has said that it is exploring all its options..
Hungary and Kyrgystan have begun DTA negotiations, the Hungarian Ministry of Foreign Affairs and Trade announced on February 28, 2018.
Morocco and Cape Verde will begin DTA negotiations in March 2018, Morocco's Tax Agency announced.
The DTA signed between Mexico and Saudi Arabia entered into force on March 1, 2018, following the publication in Mexico's official Gazette of a law ratifying the agreement on February 26, 2018.
Bangladesh and Morocco signed a DTA on March 1, 2018.
Meeting over two days ending February 28, 2018, representatives from Pakistan and the Philippines agreed to renegotiate their DTA.
The UK and Mauritius signed a DTA on February 28, 2018.
Singapore signed a DTA with Tunisia on February 27, 2018.
Bahrain's King, Hamad bin Isa Al Khalifa, has approved a law ratifying the DTA Protocol signed with the Philippines, state media reported on February 20, 2018.
The Luxembourg Government on February 23, 2018, reported it is pushing for the negotiation of an amended DTA with Oman.
According to a monthly update from the Mexican Government, Mexico's DTA with Jamaica entered into force on February 24, 2018.
According to preliminary media reports, Switzerland's upper house of parliament of February 26, 2018, approved laws to ratify the DTAs signed with Kosovo and Pakistan and a Protocol with Latvia.
The Luxembourg Government announced that it is engaged in DTA negotiations with 15 countries, in a January 29, 2018, update, including newly DTA negotiations with the UK.
Ireland and Ghana signed a DTA on February 7, 2018.
According to a statement from the President's office, Iran's Cabinet on February 18, 2018, approved the signing of DTAs with Sweden, Lithuania, and Japan.
On February 19, 2018, the Philippines Senate adopted three resolutions ratifying agreements for the avoidance of double taxation with Mexico, Thailand, and Sri Lanka.
Japan and Spain have agreed a DTA in principle, to replace their existing pact, the Japanese Ministry of Foreign Affairs announced February 21, 2018.
The Armenian Ministry of Finance said February 22, 2018, that a DTA had been initialed after four days of negotiations with Iraq.
India's Ministry of Finance on February 22, 2018, revealed that an updated DTA between India and Kenya had been published in the Official Gazette, to replace the agreement in place between the two countries since 1985.
South Africa's DTA Protocol with Brazil entered into force on February 10, 2018.
Moldova's Cabinet on January 31, 2018, approved a law to ratify the DTA signed with Georgia in November 2017.
According to preliminary media reports, Kazakhstan's Senate on February 15, 2018, approved a law to ratify a Protocol to the DTA with Azerbaijan.
Poland published an order in its Official Gazette on February 8, 2018, to bring the DTA signed with Ethiopia in 2015 into force. The agreement entered into force on February 14, 2018.
Paraguay's Government on February 11, 2018, announced the signing of a DTA with Qatar.
Guernsey's TIEA with Portugal will enter into force March 15, 2018, according to a February 20, 2018, update from the Guernsey Government.
The Botswana Government has announced that the country will sign a DTA Protocol with Zimbabwe by the end of the year.