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(August 28, 2014)
Today the UK Government has released an announcement stating that the Seychelles has committed to automatically exchanging tax information, becoming the 46th country to join the initative launched by the G5 countries of France, Germany, Italy, Spain and the UK.
At the G5 Finance Ministers' meeting in Paris on April 28, 2014, France, Germany, Italy, Spain and the UK agreed to sign competent authority agreements at the Global Forum meeting in Berlin in October, together wither early adopter countries and jurisdictions.
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(August 28, 2014)
On August 25, 2014 Switzerland and Estonia signed a protocol to amend the convention between the government of the Republic of Estonia and the Swiss Federal Council for the avoidance of double taxation with respect to taxes on income and on capital from June 11, 2002. The changes included in the protocol are a.o.:
- A building site or construction or installation project constitutes a permanent establishment only if it lasts more than 12 months (9 months under the current DTA);
- Dividend withholding tax rate is lowered to 10% (15% under the current DTA) or 0% in case of a direct shareholding of 10% in the company paying the dividends for at least 1 year prior to the payment of the dividend (5% in case of a 20% shareholding under the current DTA without a minimum holding period);
- No interest withholding tax to be withheld (10% under the current DTA);
- No royalty withholding tax to be withheld (10% (or 5% in specific cases) under the current DTA);
- Changes to the definition of a 'real-estate company' as used in Article 13 (Capital gains), paragraph 4;
- A new Article 26 (Exchange of information).
For the protocol to come into force it still has to be approved by the parliaments of both countries.
Click here to be forwarded to the text of the protocol as it is published on the website of the Swiss Federal Department, which will open in a new window.
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(August 26, 2014)
In April 2014 the governments of the United States of America and Lithuania reached an agreement in substance on a FATCA IGA to be concluded. The Agreement between the Government of the United States of America and the Government of the Republic of Lithuania to Improve International Tax Compliance and to Implement Foreign Account Tax Compliance Act was signed on August 26, 2014. The agreement is a so-called Model 1 IGA. The text of the signed IGA is now available on the website of the U.S. Department of the Treasury.
Click here to be forwarded to the text of the agreement as it is published on the website of the U.S. Department of the Treasury.
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(August 26, 2014)
On August 26, 2014 the government of the Republic of Singapore and the government of the Republic of Rwanda signed an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement will enter into force after its ratification by both countries.
The existing taxes to which the agreement shall apply are in particular: in Singapore: the income tax and in Rwanda: the personal income tax, the corporate income tax, the withholding taxes and the tax on rent of immovable properties.
Under the agreement the withholding tax rate for dividends is set at 7.5%. The withholding tax rates for interest and royalties are both set at 10%.
Click here to be forwarded to the press release issued by the Ministry of Finance of Singapore, which will open in a new window. This press release contains a link to the text of the agreement.
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(August 22, 2014)
On August 22, 2014 the Inland Revenue Authority of Singapore published the second edition of the IRAS e-Tax Guide regarding Research and Development Tax Measures. This e-Tax Guide replaces the IRAS Circular on "Research and Development Tax Measures" from October 31, 2008, which was last revised on November 6, 2013. The aim of the e-Tax guide is to set out the relevant R&D Tax measures as announced in the Budgets 2008 to 2014. The guide clarifies on the existing definition of R&D and its qualifying criteria. The guide is meant to help taxpayers self-asses if their R&D activities are qualifying R&D activities for tax purposes.
The guide provides guidance in the following areas:
- Qualifying R&D projects;
- R&D tax deductions; and
- Administrative procedures.
Click here to be forwarded to the e-Tax guide as it is published on the website of the Inland Revenue Authority of Singapore, which will open in a new window.
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