Worldwide Tax News
On 11 February 2015, the OECD published comments received in response to the public discussion draft on new OECD International VAT/GST Guidelines. The new guidelines cover the place of taxation of business-to-consumer (B2C) supplies of services and intangibles, and provisions to support the application of the Guidelines in practice.
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Poland has published the social security basis cap for 2015, which is increased to PLN 118,770 with effect from 1 January 2015. The basis cap applies for pension and disability fund contributions.
For employer contribution rates for pension and disability are 9.76% and 6.5% respectively. While those particular contributions are limited according to the basis cap, other contributions are not, such as for the illness fund, accident fund, labor fund and others. For employers, those contributions range from a combined rate of 3.22% to 7.91%.
On 6 February 2015, Venezuela published in the Official Gazette the decree setting the country's minimum monthly salary, which is increased to VEF 5,622 with effect from 1 February 2015. The minimum salary is used in determining the basis cap for social security contributions, unemployment insurance, and other benefits.
For employer social security contributions, the rates are 9%, 10% or 11% based on the risk qualification of the company with a basis cap of 5 minimum monthly salaries. For employer unemployment insurance contributions, the rate is 2% with a basis cap of 10 minimum monthly salaries.
Officials from Andorra and Portugal are scheduled to meet 26 to 27 February 2015 for the first round of negotiations for an income tax treaty. Any resulting treaty will be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.
According to recent reports, officials from Bahrain and India have recently met and discussed resuming tax treaty negotiations. Previous negotiations resulted in the initialing of an income tax treaty in 1998, but the process did not go any further. Any resulting treaty from new negotiations would be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.
The tax information exchange agreement between Guernsey and Swaziland will enter into force on 12 March 2015. The agreement was signed 3 July 2013 by Guernsey and 30 August 2013 by Swaziland, and is the first of its kind between the two jurisdictions.
The agreement applies from criminal tax matters from the date of its entry into force, and for other matters for tax periods beginning on or after that date.
The OECD announced on 24 February 2015, that the Seychelles has signed the Council of Europe-OECD Convention on Mutual Administrative Assistance in Tax Matters and amending protocol. The convention must now be ratified by the Seychelles and the ratification instrument deposited before entering into force in the country.
Seychelles signing of the Convention brings the number of signatories to 85.
The social security agreement between Switzerland and Uruguay will enter into force on 1 April 2015. The agreement, signed 11 April 2013, is the first of its kind between the two countries and generally applies from the date of its entry into force.
HM Treasury of the U.K. has issued the Double Taxation Relief (Bank Levy) (Netherlands) Order 2015 for the ratification of the pending agreement with the Netherlands for the avoidance of double taxation and the prevention of fiscal evasion with respect to bank taxes. The agreement, signed 12 June 2013, covers the Netherlands bank tax set out in the Law on bank tax, and the U.K. bank levy set out in Schedule 19 of the Finance Act 2011.
Under the agreement, when an entity resident in one country is a subsidiary of a entity resident in the other country, the first mentioned country will allow a credit against bank tax for the bank tax applied on the subsidiary by the other country. However, the credit will not be allowed if the head/parent of the group is an entity resident in the first mentioned country. The same method and restriction applies for permanent establishments.
The agreement will enter into force from the last day of the month following the month in which the ratification instruments are exchanged, and will apply from 1 January 2011.