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On June 28, 2016 the UK HM Revenue & Customs (HMRC) released the text of the Convention between the United Kingdom of Great Britain and Northern Ireland and the Oriental Republic of Uruguay for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, which was signed on February 24, 2016 (Hereafter: the DTA).
Although the DTA has been signed, it has not entered into force yet. For the DTA to enter into force, the respective ratification procedures have to have been finalized in both countries.
Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.
Read more: The HMRC publishes the text of the DTA as concluded between the UK and Uruguay
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On June 28, 2016 the OECD updated the overview of Signatories of the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA). According to the updated list Nauru has also signed the MCAA, bringing the total number of signatories to 83. According to the overview of Signatories of the MCAA and the intended first information exchange date, Nauru intends its first exchange of information to take place in September 2018.
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On June 28, 2016 the Dominican Republic and Nauru signed the (amended) Multilateral Convention on Mutual Administrative Assistance in Tax Matters. By doing so the Dominican Republic and Nauru became the 97th and 98th jurisdictions to join the Convention.
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On June 27, 2016 the following 3 BEPS Papers that were released by the New Zealand Government have been published on the website of the New Zealand Inland Revenue:
· Base erosion and profit shifting (BEPS) – update on the New Zealand work programme
· New Zealand’s plan to ensure multinationals pay their fair share of tax
· New Zealand’s taxation framework for inbound investment - A draft overview of current tax policy settings
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On June 27, 2016 the European Commission published the non-confidential version of its decision of October 21, 2015 in which it decided that a tax ruling issued by the Dutch authorities in 2008 gave a selective advantage to Starbucks Manufacturing, which according to the European Commission has unduly reduced Starbucks Manufacturing’s tax burden since 2008 by an estimate of 20 to 30 million Euros.
Read more: European Commission releases the Public version of its decision in the Starbucks case
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