31 Countries Have Now signed A Multilateral Competent Authority Agreement (MCAA) Enabling The Automatic Exchange Of Country-By-Country Reports (CbC reports) And Addressing BEPS Action 13.
31 countries have now signed a MCAA enabling the automatic exchange of CbC reports from each reporting entity between the competent authorities. The agreement handles the exchange of CbC reports as stated in BEPS action plan 13. This action plan has amended Chapter V of the transfer pricing guidelines of the OECD. The guidelines are […]
Hong Kong: Tax Information Exchange Agreements With Four Nordic Jurisdictions Entered Into Force
The tax information exchange agreements (TIEAs) signed with four Nordic jurisdictions (i.e. Denmark, the Faroes, Iceland, and Norway) in August 2014 entered into force on December 4, 2015. These TIEAs will become effective from year of assessment 2016/2017 in Hong Kong. For the other contracting jurisdictions, the TIEAs will take effect for exchange of information […]
Double Tax Treaty Between Cyprus And Switzerland Effective January 1, 2016
The first Cyprus-Switzerland double tax treaty (DTT), signed in 2014, entered into force in October 2015 with its provisions taking effect as from January 1, 2016. Under the treaty there is no withholding tax (WHT) on interest and royalties. There is also no WHT on dividends in those cases where the beneficial owner of the […]
China And Zimbabwe Signed A Double Taxation Treaty (DTT)
On December 1, 2015, China signed a DTT with Zimbabwe, bringing the number of DTTs signed by China to 104. The DTT will enter into force upon completion of the ratification procedures by both sides. The important features of ChinaZimbabwe DTT include: Withholding tax (WHT) rates on dividends, interest, and royalties paid to qualified beneficial […]
Cyprus: Proposed Tax Legislative Changes
Intellectual Property (IP) Box alignment with the OECD’s BEPS Action 5 conclusions announced, with maximum transitional arrangements The Cyprus Ministry of Finance (MoF) announced on December 30, 2015 that it will propose amendments to the current Cyprus intellectual property (IP) Box in order to introduce a new IP Box as from July 1, 2016 which […]
Korea Tax Law Changes For 2016
The Korean National Assembly has approved amendments to tax laws for 2016 which include some changes to the proposals announced in August 2015. Supporting details related to the tax law changes have also been released in amendments to relevant Enforcement Decrees. The main corporate tax law changes that may have impact on Korean inbound investors […]
India Signs Two Bilateral APA’s With The UK For Management Charges And Brand Royalty
Marking a significant development in the Advance Pricing Agreement (APA) space, India recently signed its first two bilateral APAs with the U.K. on transactions of management charges and brand royalty, avoiding seven years of potential litigation for two companies of a U.K. based group engaged in manufacturing of automotive and industrial components. The Indian APA […]