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On September 30, 2016 the Swiss Federal Council and the Swiss Federal Department of Finance (Hereafter: FDF) issued press releases announcing that on September 30, 2016 the Swiss Federal Council instructed the FDF to prepare a draft consultation paper on amending the participation deduction in connection with the too big to fail (TBTF) legislation. According to the press releases the tax burden from certain financial instruments should be reduced so that the capital accumulation of TBTF banks is not adversely affected.
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Based on the overview of Jurisdictions Participating in the Convention on Mutual Administrative Assistance in Tax Matters as available on the website of the OECD, the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters entered into force on October 1, 2016 with respect to Brazil, Nauru and Niue.
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On September 30, 2016 the Inland Revenue Department of the Hong Kong Special Administrative Region issued a press release announcing that on September 27, 2016 the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and the Government of the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, (Hereafter: the DTA) entered into force.
The fact that the DTA entered into force on September 27, 2016 means that based on Article 27, Paragraph 2 of the DTA (“Entry into Force”) the provisions of the DTA shall have effect:
(a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any year of assessment beginning on or after April 1, 2017;
(b) in Korea:
(i) in respect of taxes withheld at source, for amounts payable on or after April 1, 2017; and
(ii) in respect of other taxes, for any taxable year beginning on or after January 1, 2017.
Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.
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On September 30, 2016 the Japanese Ministry of Finance issued a press release announcing that on September 29, 2016 the exchange of diplomatic notes for the entry into force of the Protocol Amending the Convention between the Government of Japan and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, which was signed on December 11, 2015, (Hereafter: the Protocol) took place in Tokyo.
Read more: Protocol amending the Indian – Japanese DTA to enter into force
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On September 30, 2016 the Japanese Ministry of Finance issued a press release announcing that on September 28, 2016 the mutual notifications necessary for the entry into force of the Agreement between Japan and the Federal Republic of Germany for the Elimination of Double Taxation with respect to Taxes on Income and to Certain Other Taxes and the Prevention of Tax Evasion and Avoidance, as signed on December 17, 2015, (Hereafter: the DTA) were completed.
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