Get an immediate FREE trial of Orbitax's International Tax Research & Compliance Expert (ITRCE) software for 7 days.

The Tax Hub

Daily Tax Newsletter

Worldwide Tax News

Approved Changes (1)

Thailand

Responsive image

Thailand Keeps 20% Corporate Tax Rate and Introduces Measures to Promote Investment

On 13 October 2015, the Thai government announced that the cabinet has approved making permanent the 20% corporate income tax rate. The rate had been temporarily reduced from 30% to 23% in 2012 and further reduced to 20% in 2013. The reduction was set to expire then end of 2015.

The cabinet also approved a 10-year corporate and dividends tax exemption for venture capital funds with paid-up capital of at least THB 20 million that invest in certain sectors with a focus on promoting start-ups, and approved a temporary reduction in the property transfer tax rate from 2% to 0.01% for 6 months.

Proposed Changes (2)

Luxembourg

Responsive image

Luxembourg to Implement Tax Amnesty Program

On 14 October 2015, the Luxembourg government submitted a draft bill to parliament for the country's first ever tax amnesty program. The amnesty is reportedly an attempt by Luxembourg to promote disclosure prior to the beginning of tax litigation that will likely result from Luxembourg's expanding information exchange obligations with foreign tax administrations.

Under the program, taxpayers that disclose all unreported assets and pay taxes due on related income by the end of 2016 will be subject to a flat penalty of 10% of the tax amount, with no additional penalties imposed for tax evasion or fraud. If disclosed and paid by the end of 2017, the penalty is increased to 20%.

Malta

Responsive image

Malta's 2016 Budget Presented

On 12 October 2015, Malta's Minister of Finance Edward Scicluna presented the budget for 2016 to parliament. The main tax related measures introduced in the budget include:

  • Fiscal consolidation for tax purposes is introduced for groups of companies with the same ownership;
  • An R&D tax credit of up to EUR 10,000 is introduced for taxpayers that employ individual with a doctorate in science, information technology, or engineering for at least 12 months;
  • Taxpayers deriving rental income from the leasing of commercial property will be eligible for final taxation at the rate of 15% on gross rental income, excluding intragroup rental transactions;
  • The scope of supplies subject to the reduced 7% VAT rate will be expanded to include sport related activities, such as gyms, fitness centers, etc.;
  • Charitable donations to the arts will be eligible for a 150% deduction; and
  • The purchase of hybrid or electric vehicles will be eligible for a supplementary deduction of 50% of the purchase price.

Subject to approval, the changes will generally apply from 1 January 2016.

Treaty Changes (6)

Albania-Czech Rep

Responsive image

SSA between Albania and the Czech Republic Signed

On 13 October 2015, officials from Albania and the Czech Republic signed a social security agreement. The agreement is the first of its kind between the two countries, and will enter into force after the ratification instruments are exchanged.

Brunei-Luxembourg

Responsive image

Update - Tax Treaty between Brunei and Luxembourg

On 14 July 2015, officials from Brunei and Luxembourg signed an income and capital 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.

Taxes Covered

The treaty covers Brunei income tax imposed under the Income Tax Act and petroleum profits tax imposed under the Income Tax (Petroleum) Act. It covers Luxembourg individual income tax, corporation tax, capital tax and communal trade tax.

Withholding Tax Rates

  • Dividends - 0% if the beneficial owner is a company directly holding at least 10% of the paying company's capital; otherwise 10%
  • Interest - 0% if paid to a financial institution or collective investment vehicle; otherwise 10%
  • Royalties - 10%
  • Technical fees for any services of a technical, managerial or consultancy nature - 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

Brunei applies the credit method for the elimination of double taxation, while Luxembourg generally applies the exemption with progression method. However, for income covered by Articles 10 (Dividends), 11 (Interest), 12 (Royalties), 13 (Capital Gains) and 18 (Artistes and Sportspersons), Luxembourg applies the credit method.

Entry into Force and Effect

The treaty will enter into force 30 days after the ratification instruments are exchanged. It will apply in Brunei from 1 January of the year following its entry into force in respect of withholding taxes, and in respect of other taxes from 1 January of the second year following its entry into force. In Luxembourg, all provisions of the treaty will apply from 1 January of the year following its entry into force.

Ecuador-Luxembourg

Responsive image

Tax Treaty between Ecuador and Luxembourg to be Negotiated

During a meeting held 7 to 10 October 2015, officials from Ecuador and Luxembourg discussed the negotiation of an income tax treaty. Any resulting treaty would be the first of its kind between the two countries, and would need to be finalized, signed and ratified before entering into force.

Liechtenstein-Netherlands

Responsive image

Tax Treaty between Liechtenstein and the Netherlands to be Negotiated

Officials from Liechtenstein and the Netherlands met on 14 October 2015 to discuss the negotiation of an income tax treaty. Any resulting treaty would be the first of its kind between the two countries, and would need to be finalized, signed and ratified before entering into force.

Philippines-Sweden

Responsive image

SSA between the Philippines and Sweden Signed

On 15 October 2015, officials from the Philippines and Sweden signed a social security agreement. The agreement is the first of its kind between the two countries, and will enter into force on the first day of the fourth month following the exchange of the ratification instruments.

Saudi Arabia-Sweden

Responsive image

Tax Treaty between Saudi Arabia and Sweden Signed

On 19 October 2015, officials from Saudi Arabia and Sweden signed an income and capital tax treaty. The treaty is the first of its kind between the two countries.

Taxes Covered

The treaty covers Saudi Zakat and income tax including the natural gas investment tax. It covers Swedish national income tax, withholding tax on dividends, income tax on non-residents, income tax on non-resident artistes and athletes, municipal income tax and net wealth 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 a period or periods aggregating more than 183 days within any 12-month period.

Withholding Tax Rates

  • Dividends - 5% if the beneficial owner is a company holding at least 10% of the voting power or voting shares of the paying company; otherwise 10%
  • Interest - 0%
  • Royalties - 5% for royalties paid for the use of, or the right to use, industrial, commercial or scientific equipment; otherwise 7%

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;
  • 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 shares deriving more than 50% of their value directly or indirectly from immovable property situated in the other State; and
  • Gains from the alienation of shares, other than mentioned above, that form part of a participation of at least 25% in a company resident in the other State (exemption if listed on a stock exchange of either Contracting 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, for dividend income, Sweden applies the exemption method in accordance with Swedish law.

Non-Discrimination

The treaty does not include non-discrimination provisions.

Entry into Force and Effect

The treaty will enter into force on the last day of the month following the month in which the ratification instruments are exchanged, and will apply from 1 January of the year following 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

Crosss Border Rates

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

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