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Approved Changes (2)

El Salvador

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El Salvador Publishes Tax Havens List for 2018

The Salvadoran tax authority has published Guide DG-001/2017, which includes a revised list of jurisdictions and territories that are considered tax havens for tax purposes for the 2018 tax year (replaces Guide DG-001/2016). In general, payments made to recipients domiciled in a listed jurisdiction/territory are subject to an increased withholding tax of 25%. In certain cases, payments to entities under a particular preferential tax regime will be subject to increased withholding, but not the jurisdiction as a whole.

Entities in jurisdictions that are not listed may also be subject to increased withholding if meeting the statutory definition for being deemed a tax haven under Salvadoran tax law. In addition, a taxpayer may submit evidence that a listed jurisdiction does not meet the statutory definition, and if accepted may be relieved from the increased withholding tax rate.

The listed jurisdictions/territories and their status are as follows.

Low-Tax Jurisdictions/Territories

Albania, Andorra, Azores Islands (Portugal), Barbados, Bosnia and Herzegovina, Botswana, Bulgaria, Cyprus, Czech Republic, Estonia, Georgia, Gibraltar, Hong Kong, Hungary, Iceland, Ireland, Kazakhstan, Kuwait, Labuan (Malaysia), Latvia, Lebanon, Liechtenstein, Lithuania, Macau, Macedonia, Maldives, Malta, Mauritius, Moldova, Montenegro, Oman, Paraguay, Poland, Qatar, Romania, San Marino, Saudi Arabia, Serbia, Singapore, Slovenia, Switzerland (certain regimes), Taiwan, Turkey, and Uzbekistan.

The list is unchanged from the previous guide.

No-Tax Jurisdictions/Territories

Anguilla, Antigua and Barbuda, Aruba, Bahamas, Bahrain, Belize, Bermuda, British Virgin Islands, Brunei, Campione d'Italia (Italy), Cayman Islands, Cook Islands, Curacao, Delaware (United States), Dominica, Florida (United States), Grenada, Guernsey, Isle of Man, Jersey, Liberia, Marshall Islands, Monaco, Montserrat, Nauru, Nevada (United States), Norfolk Islands, Qeshm (Iran), Samoa, Seychelles, South Dakota (United States), St. Helena and Tristan Da Cunha, St. Kitts and Nevis, St. Lucia, St. Martin, St. Vincent and the Grenadines, Turks and Caicos, United Arab Emirates, U.S. Virgin Islands, Vanuatu and, Wyoming (United States).

Certain regimes of Luxembourg and Panama are removed in comparison to the previous guide.

Classified as tax havens by the OECD/FATF

The new guide includes no jurisdictions/territories as classified by the OECD/FATF.


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India Extends Initial Deadline for CbC Reports

On 25 October 2017, India's Central Board of Direct Taxes issued Circular No. 26 of 2017, which extends the deadline for furnishing a Country-by-Country report for the first year to 31 March 2018. Under India's CbC reporting requirements, the first reporting year is the fiscal year 2016-17 (beginning 1 April 2016), with the report due by the annual tax return deadline (30 November). However, since the rules for the actual furnishing of CbC reports are still under consideration (previous coverage), the first year extension is provided.

Proposed Changes (1)


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Romania to Relax New VAT Split Payment System

The Romania government is reportedly planning to relax the country's recently introduced split payment system for value added tax (VAT) (previous coverage). As introduced, the split-payment system is optional from 1 October 2017 and mandatory for most taxpayers from 1 January 2018. The mandatory obligation is to be relaxed so that it is limited to taxpayers entering bankruptcy procedures and those with a history of failing to meet their VAT obligations by prescribed deadlines.

Treaty Changes (5)


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TIEA between Guernsey and Turkey has Entered into Force

The tax information exchange agreement between Guernsey and Turkey entered into force on 6 October 2017. The agreement, signed 13 March 2012, is the first of its kind between the two jurisdictions and applies for criminal tax matters on the date of its entry and for other matters for taxable periods beginning on or after that date or, where there is no taxable period, all charges to tax arising on or after that date.

Isle Of Man-OECD

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Isle of Man Deposits Ratification Instrument for BEPS MLI

According to an update to the OECD's list of signatories and ratification status, the Isle of Man deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 25 October 2017. The Isle of Man signed the MLI on 7 June 2017 (previous coverage), with eight covered agreements (tax treaties to be impacted, subject to matching). The MLI will generally apply for a particular Isle of Man bilateral tax treaty after the other party to the treaty has deposited their ratification instrument. However, the MLI itself must first enter into force, which requires ratification by five signatories (two have deposited their ratification instrument to date - Austria and the Isle of Man).


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Dutch Lower House of Parliament Approves Tax Treaty with Zambia

On 24 October 2017, the Dutch lower house of parliament approved the pending income tax treaty with Zambia. The treaty, signed 15 July 2015 (previous coverage), 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. Once in force and effective, the new treaty will replace the 1977 tax treaty between the two countries.


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Peru Signs Mutual Assistance Convention

The OECD has announced that on 25 October 2017, Peru signed the OECD-Council of Europe Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 protocol. The Convention must now be ratified by Peru and the ratification instrument deposited before entering into force in the country.

Click the following link for the signatories to the Mutual Assistance Convention to date.

Singapore-United States

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Singapore and U.S. to Sign TIEA by Year-End

According to a joint statement published 24 October 2017, negotiations for a tax information exchange agreement (TIEA) between Singapore and the United States are substantially completed, and both sides are committed to signing the agreement, with the aim of doing so by the end of the year. Along with the TIEA, a reciprocal intergovernmental FATCA agreement will also be signed. The joint statement also notes that the two countries will continue discussions on whether to negotiate an income tax treaty.


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