rocket
Introducing the Orbitax International Tax Platform, a revolutionary suite of integrated tax solutions including research, compliance, calculations, entity management and charting. Find out more.

The Tax Hub

Daily Tax Newsletter

Worldwide Tax News

Approved Changes (4)

Brazil

Responsive image

Brazil Publishes Employee Social Security Contribution Tables for 2020

Brazil has published Ordinance No. 914 of 13 January 2020 in the Official Gazette, which sets our social security adjustments for 2020, including the monthly employee contribution rate tables. This includes the monthly rates for the first two months of the year beginning 1 January 2020, as well as the monthly rates from 1 March 2020 based on the progressive rates introduced by Constitutional Amendment No. 103 approved in November 2019.

The contribution rates based on monthly salary/wage are as follows from 1 January 2020:

  • up to BRL 1,830.29 - 8%
  • from BRL 1,830.30 to 3,050.52 - 9%
  • from BRL 3,050.53 to 6,101.06 - 11%

The contribution rates based on monthly salary/wage are as follows from 1 March 2020:

  • up to BRL 1,039.00 - 7.5%
  • from BRL 1,039.01 to 2,089.60 - 9%
  • from BRL 2,089.61 to 3,134.40 - 12%
  • from BRL 3,134.41 to 6,101.06 - 14%

The Ordinance also sets the minimum and maximum contribution basis for 2020, which may not be less than monthly salary of BRL 1,039.00 and no greater than BRL 6,101.06.

01-21-2020

Isle Of Man

Responsive image

Isle of Man Announces Changes to the VAT Treatment of Cross Border Chain-Transactions

The Isle of Man Government has published a release from Treasury on changes to the VAT treatment of cross-border chain-transactions.

---

Value Added Tax: Treatment of cross-border chain-transactions

Friday, 17 January 2020

The Treasury advises that the Value Added Tax (Place of Supply of Goods) (Amendment) Order 2020 and Value Added Tax (Amendment) Regulations 2020 have been made and came into operation on 16 January 2020, making changes to the VAT treatment of cross-border chain-transactions.

The Order inserts a new Part 4 (Chain Transactions) into the Value Added Tax (Place of Supply of Goods) Order 2004. A chain transaction is the supply of goods between three or more parties, in which the goods are delivered directly from the first party to the final customer. This Order establishes which supply within the chain should be treated as the intra-Community supply and therefore treated as zero rated for VAT purposes.

These Regulations amend Part 16 (importations, exportations and removals) of the Value Added Tax Regulations 1996. It is now a requirement for zero-rating in relation to intra-community supplies that the recipient of the supply is registered for VAT in a member State and has provided the supplier with its VAT number.

The amendments make changes that correspond to those made to the equivalent United Kingdom legislation and are required under the terms of the Customs and Excise Agreement.

A revised edition of Notice 725 will be issued in due course.

01-21-2020

Macedonia

Responsive image

North Macedonia Increases VAT Registration Threshold

North Macedonia has published a consolidated version of the Law on Value Added Tax including amendments regarding the registration threshold. This includes that with effect from 1 January 2020, the VAT registration threshold is increased from total turnover of MKD 1 million to MKD 2 million in a calendar year. Registration is required where the threshold was exceeded in the previous year, is expected to exceed the threshold when business begins, or exceeds the threshold during the year. It is also provided that, once registered, the minimum period to remain registered is three calendar years (down from five), regardless of turnover, although termination of registration is possible within a shorter period subject to approval by the competent tax authority.

01-21-2020

United States

Responsive image

U.S. IRS Willing to Consider Requests for Relief from Double Taxation Related to Repatriation

The U.S. IRS announced on 17 January 2020 that it is willing to consider requests for relief from double taxation related to repatriation tax under section 965, as amended by the Tax Cuts and Jobs Act (TCJA).

---

IR-2020-16, January 17, 2020

WASHINGTON — The IRS announced today that the agency has become aware of limited circumstances in which it may be appropriate to provide relief from double taxation resulting from application of the repatriation tax under section 965, as amended by the Tax Cuts and Jobs Act (TCJA).

The IRS has determined that in unique circumstances, such as where a corporation paid an unusual dividend for business reasons, not because of the enactment of TCJA, it may be appropriate to provide relief from double taxation. When the same earnings and profits of foreign corporations are taxed both as dividends and under section 965, double taxation could result.

The IRS is open to considering relief from such double taxation where there is no significant reduction in the resulting tax by application of foreign tax credits, such that the taxpayer would be required to pay more tax than it would have if the dividend had not been paid.

Taxpayers who have fact patterns that may fit these limited circumstances may raise them with the IRS by contacting the Office of Associate Chief Counsel (International) at 202-317-3800.

01-21-2020
Proposed Changes (1)

Philippines

Responsive image

Philippines Finance Secretary Optimistic on Passage of Remaining Tax Reform Packages in 2020

According to a release from the Philippines Department of Finance, Finance Secretary Carlos Dominguez III has expressed confidence that Congress can pass the remaining packages of the comprehensive tax reform program (CTRP) in 2020. This includes the hope that Congress can pass Package 2 of the CTRP – the proposed Corporate Income Tax and Incentives Rationalization Act (CITIRA) – in the first quarter, so that it could be signed into law by March 2020. One of the key measures of the CITIRA is a reduction of the current 30% corporate income tax rate by 2% every two years until reaching a rate of 20% in 2029. Other key measures include the reform of the fiscal incentives regime, which will be performance-based, time-bound, targeted, and made more transparent.

Further to the corporate income tax reforms, Dominguez is also optimistic for congressional approval of Packages 3 and 4 of the CTRP. Package 3 concerns real property and aims to adopt globally benchmarked valuation standards and inculcate a higher degree of professionalism in real property valuation to promote investor confidence, enhance the revenue-generating capacities of local government units and help clear right-of-way issues. Package 4 concerns passive income and financial intermediary taxation and includes measures meant to make the country more attractive for capital and long-term investments.

01-21-2020
Treaty Changes (4)

Angola-Portugal

Responsive image

Mutual Assistance Agreement between Angola and Portugal in Force

Portugal has published Notice No. 8/2020 in the Official Gazette, announcing that the agreement with Angola on mutual administrative assistance and cooperation in tax matters entered into force on 20 February 2019. The agreement, signed 18 September 2018, is the first of its kind between the two countries and applies for criminal tax matters on the date of its entry into force and for other tax matters for fiscal years beginning on or after that date or, in the absence of a fiscal year, for any tax liability arising on or after that date.

01-21-2020

France-Belgium

Responsive image

France Publishes Synthesized Text of Tax Treaty with Belgium as Impacted by BEPS MLI

The French General Directorate of Public Finance has published the synthesized text of the 1964 tax treaty with Belgium as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The text is intended to facilitate the reading of the treaty as impacted by the MLI based on the reservation and notifications deposited by the respective countries. The text is not a substitute for the respective authentic texts of the treaty and the MLI, which remain the only applicable legal instruments.

The MLI applies for the 1964 Belgium-France tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes levied by a Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 April 2019; and
  • with respect to arbitration, for cases submitted from 1 October 2019 and for cases submitted prior to that date to the extent agreed to by both Contracting States.

Click the following link for the tax treaty page of the General Directorate of Public Finance, which includes the MLI synthesized texts.

01-21-2020

Guernsey-Isle Of Man-New Zealand-Estonia

Responsive image

Guernsey Government Approves Ordinances for Ratification of Pending Tax Instruments with the Isle of Man, New Zealand, and Estonia

The Government of Guernsey has approved and submitted to parliament the ordinances for the ratification of the pending protocol to the 2013 income tax treaty with the Isle of Man, the pending protocol to the 2009 tax information exchange agreement with New Zealand, and the pending income tax treaty with Estonia.

The pending protocol to the 2013 income tax treaty with the Isle of Man was signed on 18 October 2019 by the Isle of Man and on 12 November 2019 by Guernsey. The protocol is the first to amend the treaty, including mainly BEPS-related updates, and will enter into force thirty days after the ratification instruments are exchanged.

The pending protocol to the 2009 tax information exchange agreement with New Zealand was signed on 18 September 2019. The protocol is the first to amend the agreement, including mainly BEPS-related updates, and will enter into force once the ratification instruments are exchanged.

The pending income tax treaty with Estonia was signed on 18 November 2019. The treaty is the first of its kind between the two jurisdictions and will enter into force once the ratification instruments are exchanged.

01-21-2020

Lithuania-Belgium-Israel-Luxembourg

Responsive image

Lithuania Publishes Synthesized Text of Tax Treaties with Belgium, Israel, and Luxembourg

Lithuania's State Tax Inspectorate (STI) has published the synthesized texts of the tax treaties with Belgium, Israel, and Luxembourg as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI applies for the treaties as follows:

1998 Belgium-Lithuania Tax Treaty - MLI applies:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 April 2020; and
  • with respect to modifications made to Article 25 (Mutual Agreement Procedure) by MLI Article 16, for a case presented on or after 1 October 2019, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

2006 Israel-Lithuania tax treaty - MLI applies:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019;
  • with respect to all other taxes levied by Lithuania, for taxes levied with respect to taxable periods beginning on or after 1 July 2020; and
  • with respect to all other taxes levied by Israel, for taxes levied with respect to taxable periods beginning on or after 1 January 2020.

2004 Lithuania-Luxembourg tax treaty - MLI applies:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 February 2020; and
  • with respect to modifications made to Article 26 (Mutual Agreement Procedure) by MLI Article 16, for a case presented on or after 1 August 2019, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.

MLI synthesized texts of Lithuania's tax treaties can be found on the STI tax treaty webpage.

01-21-2020
Sitemap

Powerful Tax Tools

NEW

FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.

NEW

Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.

NEW

Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.

NEW

Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.

NEW

Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.

NEW

OECD BEPS Project

Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.

NEW

Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.

NEW

Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

NEW

Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.

NEW

Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.

NEW

Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.

NEW

Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.

NEW

VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.

NEW

NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.

NEW

Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.

NEW

Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Compare Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

Get Started with Orbitax Today

With Orbitax, you get reliable and comprehensive solutions for international tax research, law change tracking, compliance and planning. Contact us today for more information and to get started with Orbitax.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More