The Tax Hub

Daily Tax Newsletter

Worldwide Tax News

Approved Changes (1)

Ukraine

Responsive image

Ukraine Clarifies Tax on Cross Border Advertising Service Payments Unaffected by Tax Treaties

Ukraine's State Fiscal Service (SFS) recently published guidance letter 13467/6/99-99-15-02-02-15, which clarifies the taxation of payments to non-residents for advertising production or distribution services. According to the letter, payments for such services by a Ukrainian resident are subject to tax at a rate of 20% regardless of where the services are rendered. The tax is a remittance tax payable by the Ukrainian resident and is not a withholding tax on the income of the non-resident. As the tax is paid by the Ukrainian resident, the rate of the tax is not affected by Ukraine's tax treaties.

Proposed Changes (2)

Gibraltar

Responsive image

Gibraltar Budget 2016 Delivered

On 5 July 2016, Gibraltar's Chief Minister Fabian Picardo delivered the Budget Address 2016. The main measures of the Budget include:

  • Import duty on a number of goods is reduced to 0%, while a 10% rate will apply on sugary drinks and on sugar, sweeteners or other derivatives used for the sweetening of drinks;
  • A new start-up incentive scheme is introduced in the form of a GIP 50,000 tax credit per year for the first three years of operations for newly established businesses, provided the business is established by 30 June 2017, employs at least five employees in the first year, and meets certain other conditions (the credit may not be carried forward);
  • The exemption threshold for individual income tax will be increased to GIP 11,500 for taxpayers in both the Allowance Based System and the Gross Income Based System; and
  • The tax base for the increased company tax rate of 20% for telecommunication companies will be adjusted so that that increased rate will only apply on the profits and gains arising from the telecommunication activities specifically mentioned in the Income Tax Act instead of all profits and gains of telecommunication companies as currently applies (standard 10% rate will apply for non-specified activities.

In the address, Chief Minister Picardo also discussed the effects and uncertainty resulting from the Brexit decision and its impact on Budget 2016. While the decision has not resulted in any major measures in the Budget, certain previously planned measures have been delayed, such as reforms in social security and pensions.

Click the following link for the full text of the Budget Address 2016.

Singapore

Responsive image

Singapore Consultation on Draft Income Tax Bill including Budget and Non-Budget Changes

On 8 July 2016, Singapore's Ministry of Finance (MoF) published a public consultation on Draft Income Tax (Amendment No. 3) Bill 2016, which includes both Budget 2016 changes and non-Budget changes. The main measures include:

  • Enhancing the Corporate Income Tax rebate from 30% to 50% of corporate tax payable for Years of Assessment (YA) 2016 and 2017, with a cap of SGD 20,000 rebate per year;
  • Enhancing the Merger & Acquisition scheme by granting the M&A allowance for the first SGD 40 million (up from SGD 20 million) of the consideration paid for qualifying M&A deals per YA till 31 March 2020;
  • Extending the Double Tax Deduction for the Internationalization scheme for four years till 31 March 2020;
  • Extending the upfront certainty of non-taxation of companies’ gains from disposal of equity investments till 31 May 2022; and
  • Enabling implementation of Country-by-Country (CbC) reporting with effect for financial years commencing on or after 1 January 2017 for Singapore-headquartered MNE groups with global revenue exceeding SGD 1.125 billion, with the CbC report due within 12 months from the last day of the financial year.

Click the following link for the consultation page on the MoF website for additional information. Comments are due by 29 July 2016.

Treaty Changes (5)

Argentina-Germany

Responsive image

Argentina and Germany to Resume SSA Negotiations

According to a release from the German Federal Ministry of Labor and Social Affairs, officials from Argentina and Germany have agreed to resume negotiations for a social security agreement, which were last held in 2013. The agreement will be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.

Armenia-Russia

Responsive image

Protocol to tax Treaty between Armenia and Russia Tax Treaty in Force

According to a recent update from the Armenian government, the 2011 protocol to the 1996 income and capital tax treaty with Russia entered into force on 15 April 2013. The main changes made by the protocol include:

  • Article 4 (Resident) is amended with the addition of the provision that if a company is considered resident in both Contracting States, the benefits of the treaty will not apply unless the competent authorities reach mutual agreement on the company's residence for the purpose of the treaty;
  • Article 5 (Permanent Establishment) is amended by reducing the time period for a construction PE to be deemed constituted from 18 months to 12 months;
  • Article 10 (Dividends) is amended by adding the provision that the 5% withholding tax rate for dividends will apply when the beneficial owner directly holds at least 25% of the paying company's capital;
  • Article 11 (Interest) is amended by adding a 10% withholding tax rate on interest payments (originally no withholding tax);
  • Article 12.1 (Capital Gains) is added, which provides that 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;
    • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other State; and
    • Gains from the alienation of shares or other rights in a company, where more than 50% of the company's assets consist directly or indirectly of immovable property situated in the other State;
  • Article 25 (Assistance in Tax Collection) is renamed and replaced (updated); and
  • Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standard for information exchange.

The protocol generally applies from 1 January 2014, although the changes in Articles 25 (Assistance in Tax Collection) and 26 (Exchange of Information) apply from the date of its entry into force.

Belgium-Panama

Responsive image

TIEA between Belgium and Panama to be Negotiated

According to recent reports, officials from Belgium and Panama have agreed to begin negotiations for a tax information exchange agreement. Any resulting agreement would be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.

Chile-OECD

Responsive image

Chile Deposits Ratification Instrument for Mutual Assistance Convention

On 7 July 2016, Chile deposited the ratification instrument for the OECD-Council of Europe Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 protocol. Chile signed the Convention as amended on 24 October 2013.

According to the OECD overview of signatories to the convention, the Convention will enter into force in Chile on 1 October 2016.

Czech Rep-Kazakhstan

Responsive image

Protocol to Tax Treaty between the Czech Republic and Kazakhstan has Entered into Force

The 2014 protocol to the 1998 income and capital tax treaty between the Czech Republic and Kazakhstan entered into force on 28 June 2016. The main changes made by the protocol include:

  • Article 10 (Dividends) paragraph 3 is replaced to clarify the definition of dividends;
  • Article 11 (Interest) paragraph 3 is replaced to clarify the exemption from withholding tax on interest paid to a government of a Contracting State or in connection with a loan or a credit guaranteed by the Government of a Contracting State;
  • Article 13 (Capital Gains) paragraph 2 is replaced to clarify the taxation of capital gains from the alienation of shares deriving more than 50% of the value directly or indirectly from immovable property situated in a Contracting State;
  • Article 23 (Elimination of Double Taxation) is replaced, although both Contracting States continue to generally apply the credit method under the treaty; and
  • Article 26 (Exchange of Information) is replaced to bring it in line with the OECD standard for information exchange.

The protocol generally applies from 1 January 2017, although changes in Article 26 (Exchange of Information) apply from the date of its entry into force.

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

Worldwide Tax Treaties

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

Get an immediate FREE trial of Orbitax ITRCE

Get Started with Orbitax Today

With Orbitax, you get reliable and comprehensive solutions for international tax research, compliance and planning. Contact us today 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