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A delegation from the Mexican Government met with officials from the regulatory body of Brazil’s Manaus Free Trade Zone on February 4, 2015, to study the structure of the free zone.

The visit followed an announcement by the Mexican Government that it plans to establish three special economic zones (SEZs) in the southern states of Guerrero, Chiapas, and Oaxaca to boost development in the region.

The delegation was led by Mexico’s Ambassador to Brazil, Beatriz Paredes, and included a number of officials from the Mexican Ministry of Finance.

In August last year, the Brazilian Government enacted legislation extending the validity of the Manaus Free Trade Zone until 2073. The tax incentives of the zone had been due to expire in 2023.

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In a recent letter to the Committee on Foreign Relations, the American Institute of Certified Public Accountants (AICPA) requested that the US Senate urgently approve all pending bilateral double taxation agreements (DTAs) and protocols.

The AICPA pointed out that the full Senate has not approved any DTA or protocol since 2010. Their passage has been blocked to date by Senator Rand Paul (R – Kentucky) on the grounds that they would allow for US citizens’ privacy to be invaded by revealing their tax records to other countries.

However, the association wrote that “income tax treaties are vital to US economic growth as well as US trade and tax policy. Tax treaties assist in harmonizing the tax systems of treaty nations and in providing certainty on permanent establishment rules, a mechanism to relieve double taxation, and other key issues faced by businesses of all sizes that operate internationally.”

“DTAs apply to both companies and individuals who are engaged in cross-border transactions,” it added. “As cross-border trade and investment activities expand, tax treaties remain pivotal in preventing the imposition of excessive or inappropriate taxes. … Outdated tax treaties increase the potential for double taxation as well as hinder the ability of the Internal Revenue Service and foreign tax authorities to cooperate in the fair and efficient enforcement of tax laws.”

In addition, the AICPA noted that “outdated tax treaties increase the potential for double taxation as well as hinder the ability of the Internal Revenue Service and foreign tax authorities to cooperate in the fair and efficient enforcement of tax laws.”

The treaties in question include the new DTA and associated protocol with Chile, which would be only the second such agreement for the US in South America, and which would lower or remove withholding taxes on interest and dividend. An amended DTA with Hungary would close a “loophole that currently allows non-residents of the two treaty partners to obtain US tax benefits by inserting Hungarian companies with no economic substance with the principle purpose of providing access to the treaty for those non-residents.”

In addition, the pending protocols with Luxembourg and Switzerland would update tax information exchange provisions with those countries. For example, AICPA said that the latter, if ratified, would “specifically protect Americans against indiscriminate searches of information by either country by limiting the administrative assistance to individual cases.”

Other treaties awaiting ratification by the US are the new version of the bilateral DTA with Poland, and also an amendment to the existing agreement with Spain.

The AICPA said: “Until 2010, income tax treaties and protocols were timely acted on by the Senate. We respectfully request prompt consideration and approval of these pending tax treaties and protocols.”

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Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017.

Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending the completion of respective national approval procedures, for it to be applied from January 1, 2017.

The new DTA is based on the Organisation for Economic Cooperation and Development’s (OECD’s) model agreement, and covers income and capital. It will replace a 1995 agreement currently in force, which governs only the taxation of certain income. Maximum withholding tax rates for dividends, interest, and royalty income will be prescribed by the new DTA, with confirmation of these rates when the text of the DTA is published after its signature.

The DTA will also cover the taxation of AHV pensions. These will be taxed solely in the state of residence. In the case of cross-border commuters, the respective state of residence will continue to retain the right of taxation.

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7 January 2015, the Abu Dhabi Global Market (ADGM) published draft legislation covering its operations for consultation. The new financial free zone will have its own administration, court system and tax incentives to attract banks and companies from around the world.

Under the proposals, the ADGM will follow the Dubai International Financial Centre (DIFC) in basing its legal framework on English common law. “English common law, as it stands from time to time, will therefore govern matters such as contracts, tort, trusts, equitable remedies, unjust enrichment, damages, conflicts of laws, security, and personal property,” ADGM said in one of six consultation papers.

It will also seek to adopt the most effective legislation from around the world. “ADGM has the opportunity to take the best of the UK approach, while avoiding some of its historic peculiarities that have been removed or abandoned by the best practice of other jurisdictions,” it said. For example, shares in ADGM companies will not have a par value, in line with the approach taken in jurisdictions such as Hong Kong, Singapore and Australia.

It will also introduce a new type of “restricted scope company” with lighter disclosure and compliance requirements which, it said, would be “holding vehicles for professional investors and limited instances of institutions for whom less regulation and a greater degree of confidentiality will be appropriate.” The ADGM is further considering extending this regime to include entities owned entirely by an individual or close family members.

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MILAN: An uptick in car sales, stable home prices and consumer confidence, and second thoughts on growth prospects at the Bank of Italy are the latest indicators that Italy’s long recession might finally be drawing to a close.

In each of the last two years, brief hopes of an economic recovery were dashed by negative growth and a new slump in industrial production. That could happen again this time, though many economists say they are looking at the latest developments with cautious optimism.

“Things are moving in the right direction,” Luca Paolazzi, chief economist with the industrial association Confindustria, told Italian reporters this week. “The new data is comforting; this could be the year the cycle reverses itself.”

The indicators are not insignificant. The Ministry of Transportation reported that new car registrations, an important indicator in an automobile-loving country like Italy, rose to just over 131,000 in January — an 11 percent increase compared to the same month in 2014. That’s the biggest year-on-year increase in at least four years.

Meanwhile, ISTAT, Italy’s National Statistics Institute says consumer confidence levels are holding steady so far this year after steadily falling for the second half of 2014.

The same for bankers, who say Italian home prices, which have fallen steady since mid-2013, are showing signs of leveling out.

Perhaps more importantly, the Bank of Italy has adjusted its economic growth projections upward, albeit by a small margin. The latest prognostications say the Italian economy will grow 0.5 percent this year, up ever so slightly from projections for 0.4 percent growth at the start of the year.

“The Bank of Italy growth projections may not sound like much, and they are still below projections for the European Union as a whole, but compared to the last couple of years, it is good news,” Javier Noriega, chief economist with Hildebrandt and Ferrar, told Xinhua, referring to a 0.5 percent contraction in 2014 and a 1.9 per cent contraction a year earlier.

A big factor in the growth estimates is the weak euro, which makes Italian exports cheaper and makes Italy a more attractive destination for foreign tourists both oversized factors in Italy. Falling oil prices are also relevant, lowering transport costs and further increasing foreign demand for Italian products.

Regardless of the reasoning, if the projections hold, or if they are further adjusted upward, it would be very positive news for Italy.

In that scenario, the country would see debt shrink in terms of gross domestic product and it would allow tax revenue to climb without increasing tax rates. That would help reduce fears Italy could be headed to a new debt crisis, pushing yields on Italian debt lower and reducing government spending by making it cheaper to borrow money.

“Things are moving in the right direction,” Luca Paolazzi, chief economist with the industrial association Confindustria, told Italian reporters this week. “The new data is comforting; this could be the year the cycle reverses itself.”

The indicators are not insignificant. The Ministry of Transportation reported that new car registrations, an important indicator in an automobile-loving country like Italy, rose to just over 131,000 in January — an 11 per cent increase compared to the same month in 2014. That’s the biggest year-on-year increase in at least four years.

Analysts also said a strong economy would help the support levels for Prime Minister Renzi, making it easier for him to push his reform agenda.

“One good thing could lead to another very neatly,” Noriega said. “But it all depends on the positive news continuing. Everything gets reset if it’s another false alarm.”

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The Tax Information Exchange Agreement between Jersey and Hungary entered into force today, 13 February 2015.

The Agreement generally applies from 13 February 2015.

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The International Monetary Fund (IMF) has expressed support for Egypt’s efforts to broaden the tax base, encouraging the swift implementation of a modern value-added tax (VAT).

The Egyptian Government plans to replace the current sales tax with a fully fledged VAT in the spring. A draft law following international standards has been prepared, and the tax administration is finalizing preparatory steps. A rate for the new VAT has not yet been set, but a rate of between 10 and 12 percent has been mooted and would be levied on a wide range of goods and services.

Work is also underway to develop a simplified tax regime for small and medium enterprises (SMEs) alongside the introduction of VAT. Egypt is also in the process of enhancing the systems used to administer taxes in an effort to improve tax compliance rates.

The IMF said in its Article IV consultation report with Egypt that the measures could help the Government achieve its plan to cut the budget deficit to 8-8.5 percent of gross domestic product (GDP) by 2017. However, the Fund said that authorities should be prepared to take contingency measures if the reforms do not fully deliver the expected revenues. Possible measures could include setting a higher VAT rate or scheduling a future increase. Property taxation could also be increased, it said.

Aside from the new VAT, the Egyptian Government’s 2014/15 Budget included the introduction of taxes on dividends and capital gains, a five percent additional tax on affluent taxpayers, increases to excise duties on tobacco and alcohol, and a revamped property tax.

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The Organisation for Economic Cooperation and Development (OECD) has recommended that Australia reduce its company tax rate and broaden the tax base.

The suggestion is made in the OECD’s new report, Economic Policy Reforms 2015: Going for Growth. The report argues that improving the efficiency of the tax system should be a key priority for the Australian Government. It says: “Consumption taxes are relatively low while income taxes are heavy. This partially reflects a high headline company tax rate, especially for a capital-importing country like Australia.”

The report notes that the 2014 Budget included plans for a 1.5 percent cut in the company tax rate from July 2015. However, Prime Minister Tony Abbott has in recent weeks said that the Government will introduce what he describes as a “small business tax cut,” which will be “at least as big as the 1.5 percent already flagged.” Business organizations have criticized Abbott’s statements as foreshadowing a move toward a “two-tier” company tax system, and they have urged the Government to implement a rate cut for all businesses.

Abbott has also made clear that while all options for tax reform are “on the table” as part of the simultaneous Tax and Federation White Paper processes, no changes can be made to the goods and services tax (GST) system without the consent of the states and territories.

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On February 10 in Tokyo, Japan’s Prime Minister, Shinzo Abe, and his Mongolian counterpart, Chimed Saikhanbileg, signed an economic partnership agreement (EPA) between their two countries.

Negotiations towards the EPA began in 2012. The deal includes an agreement that both countries will lower almost all of their tariffs on goods over a period of 10 years.

Mongolia will remove its import duty on most Japanese cars, while Japan will eliminate its tariffs on the majority of Mongolia’s exports of industrial products (including cashmere) over the same period. Japan will also reduce its duty on Mongolian processed beef, subject to a quota.

Passenger vehicles and their components amount to more than half of Japan’s total exports to Mongolia, which totaled some USD290m in 2013. Mongolia’s exports to Japan, which are intended to be boosted by the EPA, currently consist mainly of coal and other natural resources, and outflows were worth just over USD20m in the same year.

Completion of the EPA is also intended to ensure that Japan can access stable future supplies of rare earths, which are used by its motor industry. Such supplies from China have been put in doubt after China replaced its export quotas, which were challenged before the World Trade Organization, with a licensing system, on top of high export duties.

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The European Free Trade Association (EFTA) said that it sent a delegation to Georgia on February 4, 2015, to discuss a timeframe for free trade negotiations.

At the meeting, the two sides decided to aim for a comprehensive free trade agreement (FTA) covering trade in goods, trade in services, investment, intellectual property rights, competition, government procurement, trade and sustainable development, and legal and institutional issues, including dispute settlement.

A first round of talks is planned for the summer of 2015 with the intention of concluding negotiations within a year.

The EFTA member states – Iceland, Liechtenstein, Norway and Switzerland – signed a Joint Declaration on Cooperation with Georgia in 2012 to further enhance their bilateral economic relations.

Trade between the EFTA states and Georgia has grown significantly in recent years. Georgia’s main exports to EFTA states are mainly mineral fuels/oil and aluminum. EFTA states mainly export pharmaceutical products, clocks and watches, and fish and marine products.

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