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Approved Changes (2)
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OECD Publishes Updated Transfer Pricing Profiles for 31 Countries

The OECD has announced the publication of updated versions of transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonized information on key aspects of transfer pricing legislation, provided by countries themselves.

Thailand

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Thailand Increase Maximum Monthly Social Security Contribution

The National News Bureau of Thailand has published a release on an increase in the maximum monthly social security contribution basis cap for both employers and employees. Currently, the salary basis cap is THB 15,000 per month, resulting in a maximum monthly contribution of THB 750 (5% of salary) for both employers and employees. From January 2018, Thailand's Social Security Office will increase the monthly salary basis cap to THB 20,000, resulting in a maximum monthly contribution of THB 1,000.

Treaty Changes (5)

China-Liechtenstein

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Tax Treaty between China and Liechtenstein under Negotiation

Officials from China and Liechtenstein met 30 October to 1 November for the negotiation of an income tax treaty. Any resulting treaty would be the first of its kind between the two countries, and must be finalized, signed, and ratified before entering into force.

India-Italy

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Protocol to Tax Treaty between India and Italy under Negotiation

Officials from India and Italy met 30 October 2017 to discuss bilateral relations, including ongoing negotiations for an amending protocol to the 1993 income tax treaty between the two countries. Any resulting protocol would be the second to amend the treaty, and must be finalized, signed, and ratified before entering into force.

Kuwait-Kyrgyzstan

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Tax Treaty between Kuwait and Kyrgyzstan has Entered into Force

According to a recent update from the Kyrgyzstan government, the income and capital tax treaty with Kuwait entered into force on 23 May 2017. The treaty, signed 13 December 2015, is the first of its kind between the two countries.

Taxes Covered

The treaty covers Kuwaiti corporate income tax, income tax of the Neutral Zone, and tax subjected according to the Supporting of National Employees. It covers Kyrgyz tax on profits and income of legal persons, and individual income tax.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise of one Contracting State furnishes services in the other State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months.

Withholding Tax Rates

  • Dividends - 0%
  • Interest - 0%
  • Royalties - 10%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State; and
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State.

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation.

Effective Date

The treaty applies in respect of withholding taxes from 1 January 2018 and in respect of other taxes for taxation years beginning on or after 1 January 2017.

Paraguay-Qatar

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Tax Treaty between Paraguay and Qatar to be Signed

On 1 November 2017, the Qatari Cabinet approved the signature of an income tax treaty with Paraguay. The treaty will be the first of its kind between the two countries, and must be signed and ratified before entering into force.

Rwanda-Untd A Emirates

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Tax Treaty between Rwanda and the U.A.E. Signed

On 1 November 2017, officials from Rwanda and the U.A.E. signed an income tax treaty. The treaty is the first of its kind between the two countries and will enter into force after the ratification instruments are exchanged. Details of the treaty will be published once available.

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