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Worldwide Tax News

Approved Changes (1)

Romania

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Romania Introduces Changes to Micro-Enterprise Tax Regime including New Rates

Romania's government has recently approved an emergency ordinance making changes to the country's micro-enterprise tax regime. The changes are in addition to changes made in September 2015 (previous coverage). The additional changes include:

  • An increase in the revenue threshold from EUR 65,000 to EUR 100,000 for the micro-enterprise tax regime to apply; and
  • New rates applicable as follows:
    • 1% on the revenue of micro-enterprises with two or more employees;
    • 2% on the revenue of micro-enterprises with one employee; and
    • 3% on the revenue of micro-enterprises with no employees.

The changes apply from 1 January 2016.

Treaty Changes (6)

Brazil-Switzerland

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TIEA between Brazil and Switzerland Signed

On 23 November 2015, officials from Brazil and Switzerland signed a tax information exchange agreement. The agreement is the first of its kind between the two countries. It will enter into force once the ratification instruments are exchanged, and will apply from that date for requests made in respect of taxable periods beginning on or after 1 January of the year following its entry into force.

Curacao-Malta

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Update - Tax Treaty between Curaçao and Malta

The income tax treaty between Curaçao and Malta was signed on 18 November 2015. The agreement is the first of its kind between the two countries.

Taxes Covered

The treaty covers Curaçao income tax, wage tax, profit tax and dividend tax. It covers Malta income tax.

Withholding Tax Rates

  • Dividends -
    • Paid from Curaçao to Malta beneficial owner: 0% if the beneficial owner is a company in Malta directly holding at least 10% of the paying company's capital; otherwise 5%
    • Paid from Malta to Curacao beneficial owner: Limited to the amount of Malta tax on the profits out of which the dividends are paid
  • Interest - 0%
  • Royalties - 0%

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; and
  • Gains from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated 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

Malta applies the credit method for the elimination of double taxation, while Curaçao may apply the exemption or credit method depending on the type of income and the applicable provisions of its domestic law.

Entry into Force and Effect

The treaty will enter into force on the first day of the first month following the exchange of the ratification instruments, and will apply from 1 January of the year following its entry into force.

Egypt-Netherlands

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New Tax Treaty between Egypt and the Netherlands under Negotiation

According to recent reports, officials from Egypt and the Netherlands met 25-29 October 2015 for the first round of negotiations for a new income tax treaty. Any resulting treaty will replace the 1999 income tax treaty between the two countries, which currently applies, and must be finalized, signed and ratified before entering into force.

Israel-OECD

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Israel Signs Mutual Assistance Convention

The OECD has announced that on 24 November 2015, Israel 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 Israel and the ratification instrument deposited before entering into force in the country.

Kenya-Saudi Arabia

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Tax Treaty between Kenya and Saudi Arabia to be Signed

On 23 November 2015, the Saudi Cabinet authorized the Ministry of Finance to sign an income tax treaty with Kenya. The treaty will be the first of its kind between the two countries, and must be finalized, signed and ratified before entering into force.

Slovak Republic-Untd A Emirates

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Tax Treaty between the Slovak Republic and the U.A.E. to be Negotiated

Officials from the Slovak Republic and the United Arab Emirates have agreed to the negotiation of an income tax treaty during a meeting held 18-19 November 2015. 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.

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