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Approved Changes (3)

Argentina

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Argentina Reduces Personal Income Tax for Certain Employees

On 7 May 2015, Argentina published General Resolution 3770/2015 in its Official Gazette. The resolution includes a measure for the reduction in personal income tax for employees earning between ARS 15,000 and ARS 25,000 per month as announced by Argentina's Minister of Economy Axel Kicillof on 4 May 2015. The reduction is in the form of a 20% increase in the allowable standard personal deductions.

The measure applies retroactively from 1 January 2015, and any excess tax already withheld is to be reimbursed in five equal monthly installments.

Italy

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Italy Clarifies Effective Date of the Energy Tax Surcharge Repeal and Related Matters

On 28 April 2015, the Italian Revenue Agency issued Circular No. 18/2015 clarifying the effective date for the repeal of the energy tax surcharge on oil and energy companies, which was ruled unconstitutional on 9 February 2015 by the Italian Constitutional Court (previous coverage).

The Circular clarifies that the ruling of the court has no effect on any tax year ending before 12 February 2015, the day after the decision was published. Therefore, any company subject to the tax with a tax year ending up to 11 February 2015 must still pay the tax by the deadline, which is generally by the 16th day of the 6th month following the close of the tax year.

The circular also clarifies that net operating losses carried forward may still be considered in determining the taxable base for the energy tax surcharge and whether the taxable income threshold (EUR 300,000) for the surcharge to apply is met. In addition, the cap for utilizing any energy tax surcharge credit remains EUR 700,000.

Saudi Arabia

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Saudi Arabia Announces 1 June Effective Date for New Rules Allowing Foreign Investment in the Stock Market

On 4 May 2015, the Saudi Capital Market Authority announced that the rules for qualified foreign investors (QFI) to invest in the Saudi Stock Market have been finalized and will be effective 1 June 2015. The Stock Market is planned to open to foreign investment on 15 June 2015.

QFI Conditions

The general conditions to register as a QFI include that the applicant must:

  • Be a financial institution with a legal personality which falls within one of the following types:
    • Banks;
    • Brokerage or securities firms;
    • Fund managers; or
    • Insurance companies;
  • Be licensed or otherwise subject to regulatory oversight by a regulatory authority and incorporated in a jurisdiction that applies regulatory and monitoring standards equivalent to those of the Saudi Capital Market Authority or acceptable to it;
  • Have at least SAR 18,750,000,000 (~USD 5 billion) or equivalent amount in assets under management, although this amount may be reduced to as low as SAR 11,250,000,000 (~USD 3 billion) ; and
  • Have carried out securities-related activities and investment for at least 5 years

Limitations

Investment limitations include:

  • A foreign investor, together with its affiliates, may not own more than 5% of the shares of any one listed company;
  • No more than 20% of the shares of a listed company may be owned by foreign investors; and
  • The aggregate foreign ownership of all listed companies is limited to 10% of the total Stock Market value, including any interests under swaps

Taxation

Capital gains from the disposal of shares on the Stock Market are generally tax exempt, and dividends are subject to 5% withholding tax.

Click the following link for additional information, including the full rules and a FAQ on the Saudi Capital Market Authority website.

Proposed Changes (1)

Greece

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Greece Plans Tax Amnesty for Funds Held Abroad

Greek's Finance Minister Yanis Varoufakis has announced plans to introduce a tax amnesty scheme for taxpayers with undeclared funds held abroad. Under the scheme taxpayers that declare such funds will be subject to tax at rates of 15% to 20%, with no risk of investigation or further penalties.

Treaty Changes (3)

Austria-Montenegro

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Tax Treaty between Austria and Montenegro has Entered into Force

On 21 April 2015, the income and capital tax treaty between Austria and Montenegro entered into force. The treaty, signed 16 June 2014, is the first of its kind between the two countries.

Taxes Covered

The treaty covers Austrian income tax, corporation tax, land tax, the tax on agricultural and forestry enterprises, and the tax on the value of vacant plots. It covers Montenegro corporate profit tax and personal income tax.

Withholding Tax Rates

  • Dividends - 5% if the beneficial owner is a company directly holding at least 5% of the paying company's capital, otherwise 10%
  • Interest - 10%
  • Royalties -
    • 5% for any copyright of literary, artistic or scientific work including cinematographic films and recordings on tape or other media used for radio or television broadcasting or other means of reproduction or transmission or computer software
    • 10% for any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience

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 generally apply the credit method for the elimination of double taxation. However, if an Austrian resident is engaged in substantive active business operations in Montenegro and derives income that may be taxed in Montenegro under the provisions of Article 7 (Business Profits), Austria will exempt such income from tax. Austria will also exempt income from employment that may be taxed in Montenegro under the provisions of Article 14.

Effective Date

The treaty applies from 1 January 2016.

China-Russia

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Protocol to the New Tax Treaty between China and Russia Signed

On 8 May 2015, officials from China and Russia reportedly signed a protocol to the pending 2014 income tax treaty between the two countries. The protocol provides for an exemption from withholding tax on interest arising from loans in one Contracting State paid to a resident of the other state.

The protocol will enter into force after the ratification instruments are exchanged.

Hong Kong-Saudi Arabia

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Tax Treaty between Hong Kong and Saudi Arabia under Negotiation

According to a recent update published by the Hong Kong Inland Revenue Department, officials from Hong Kong and Saudi Arabia will meet 12 to 14 May 2015 for the third round of negotiations for an income tax treaty. Any resulting treaty will be the first of its kind between the two jurisdictions and must be finalized, signed and ratified before entering into force.

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