VIRTUAL PERMANENT ESTABLISHMENT Presented by Mustapha Ndajiwo UNISA/FIRS
|
|
|
- Jordan McCormick
- 5 years ago
- Views:
Transcription
1 VIRTUAL PERMANENT ESTABLISHMENT Presented by Mustapha Ndajiwo UNISA/FIRS
2 INTRODUCTION
3 PERMANENT ESTABLISHMENT The profits of an enterprise of a Contracting State shall be taxable only in that state unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. The term `permanent establishment means a fixed place of business through which the business of the enterprise is wholly or partly carried on The term permanent establishment includes especially: (a) a place of management, (b) a branch, (c) an office, (d) a factory, (e) a workshop, (f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.
4 WHY IS IT AN ISSUE FOR AFRICA? E-commerce is growing in Africa: By 2018, the African e-commerce market will grow to US$ 50 billion, from just US$ 8 billion in (International Trade Centre 2015) Corporate Income Taxes are the most significant taxes for developing countries as a share of all tax revenue in comparison to higher income countries. (Crivelli, et al 2015). Development financing is critical the opportunity cost of not taxing e-commerce means lesser funds available for financing development
5 5 Jumia Group, formerly known as African Internet Group was founded in Nigeria in It has Germany s Rocket Internet as its parent company situated in Germany, and also has Goldman Sachs, Orange and South African telecoms group MTN among its shareholders. The Group owns a number of technology-based firms across 22 African Countries, and in 2016, it was valued at 1 billion US dollars. The most notable of the group s companies is the Jumia.com, which is often referred to as the Amazon.com of Africa. According to Rocket Internet annual report (2017), Jumia.com is yet to make any profits yet Mustapha Ndajiwo
6 WEBSITE/SERVER AS PE
7 ARGUMENTS AGAINST VIRTUAL PE 7 Compliance cost would be high because e-commerce companies may not have a physical presence and will be operating in a different jurisdiction without offices and personnel. In respect of digitized products, where shipping documents are absent, there may not be an existing and reliable means of establishing the jurisdiction of the e-commerce transaction. Certainty and Simplicity: if source country taxation is conditional on a threshold, e-commerce companies may be unaware if their economic presence in a certain jurisdiction will exceed the threshold, thereby qualifying for a PE in the jurisdiction. E-commerce companies may spread their activities to other jurisdictions to avoid threshold Mustapha Ndajiwo
8 EMERGING ISSUES France and others: Impose an equalisation tax on the turnover generated by the digital companies in Europe India: equalisation levy of 6% to 8% is imposed on the gross payment on services such as online advertising, cloud computing, software downloads and web hosting received by foreign companies without a permanent establishment in India. In a case between Dell and Spain: even though Dell Ireland did not have a physical presence in Spain the court ruled against Dell because it sold goods to Spain through a website dedicated to the market in Spain. The server that hosted the website was also not in Spain in this case, and no employees of the company were resident in Spain. The court ruled that all revenue derived from the sales through the website to the Spanish market should constitute a PE. (Sengupta 2013)
9 Issues 9 There is strong evidence that e-commerce is growing in Africa, however efforts to tax the digital economy remain subtle New approaches suggest that there is a shift from taxing profits to taxing transactions (Double incidence on indigenous taxpayers) Unilateral approaches (Mostly quick wins ) are being explored by countries due to the lack of consensus and perceived difficulty of addressing the issues The negative externalities birthed by e-commerce technology with regards to tax policy may require more investment in technological based solutions, however the discussions are reluctant Mustapha Ndajiwo
10 The way forward A multi-jurisdictional approach that involves the use of software to determine PE by an economic presence threshold through the sales of goods and services. (may involve third parties) The use of real-time exchange of relevant information on transactions conducted via e-commerce Agreed standards for software solutions The use of Software to identify location of parties to transaction
11 FURTHER RESEARCH Allocation of profits Valuing Intangibles for tax purposes Formulary apportionment? Valuing and Taxing Data?
12 CONCLUSION 12 The Virtual Permanent Establishment is currently the best option for broadening the definition of PE. The use of technology to ascertain the level of economic activities in a jurisdictions to determine nexus will go a long way in achieving this. To achieve the aforementioned, it is necessary to engage in further international collaboration and a consensus on how to use technology to address the impasse caused by e-commerce. Mustapha Ndajiwo
13
Permanent Establishment through Digital Presence Will it work?
Permanent Establishment through Digital Presence Will it work? Himanshu Parekh 8 December 2018 Background BEPS Action Plan 1 Digital Economy is a result of Information and Communication Technology Technologies
e-commerce and Transfer Pricing
e-commerce and Transfer Pricing Richard Hiemstra 20 November 2017 Contents The digital economy Corporate Tax: what is the issue? Google and Amazon EU Commission Communication Existing rules Longer Term
Taxation of digital economy
Taxation of digital economy CA Jasdeep Sahni WIRC 15 December 2018 Contents Conventional commerce Digital economy India tax considerations Summing up 2 Conventional commerce Conventional commerce Retailers
Budget 2017 May Bring More Tax Pain For Digital Transactions
s Budget 2017 May Bring More Tax Pain For Digital Transactions by Payaswini Upadhyay Updated on December 8, 2016, 4:49 pm December 8, 2016, 3:31 pm After taxing Indian advertising on foreign digital platforms
Double Taxation Agreement between India and Bangladesh
Double Taxation Agreement between India and Bangladesh Signed on May 27, 1992 This document was downloaded from the Dezan Shira & Associates Online Library and was compiled by the tax experts at Dezan
16 March :00 16:00 (CET)
16 March 2018 15:00 16:00 (CET) Join the discussion Ask questions and comment throughout the webcast: CTP.Contact@oecd.org @OECDtax or #OECDTaxTalks 2015 Action 1 Report Digitalisation of the economy,
E-Commerce structures & tax issues
E-Commerce structures & tax issues CA Jasdeep Sahni WIRC, Mumbai 1 September 2018 Contents Traditional commerce E- commerce and related tax considerations Recent amendments under the Income-tax Act, 1961
Digital Economy. Dr. Amar Mehta October Chambers Of Tax Consultant, Mumbai.
Digital Economy Chambers Of Tax Consultant, Mumbai Dr. Amar Mehta October 2018 Categories 1 OECD s BEPS Action 1 Final Report 4 Digital PE: The EU Version 7 Italy 2 OECD s BEPS Interim Report Action 1
a) effective places of management, branches, offices, factories, workshops, warehouses, shops and other establishments.
How to identify a permanent establishment in Spain? The identification of a Permanent Establishment (hereinafter PE ) in Spain of a non-resident entity first depends on the State in which such entity is
REQUEST FOR INPUT ON WORK REGARDING THE TAX CHALLENGES OF THE DIGITALISED ECONOMY
OECD c/o Mr. David Bradburry 2 Rue André Pascal 75775 Paris France Author Phone Telefax E-Mail Date Pe/JT E 09/17 +49 30 278 76 310 +49 30 278 76 799 trommer@dstv.de 18.10.2071 REQUEST FOR INPUT ON WORK
Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September
Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September 18, 2007 Effective date: In the P.R.C., from January
Fair Taxation of the Digital Economy: What is Fair? 2018 KPMG EMA Tax Summit Rome
Fair Taxation of the Digital Economy: What is Fair? 2018 KPMG EMA Tax Summit Rome Panel Chris Morgan Head of Global Tax Policy E: christopher.morgan@kpmg.co.uk Robert Van der Jagt Chairman of KPMG's EU
TAXATION OF NON-RESIDENTS. (Non-resident Income Tax) INCOME ACCRUED FROM 1 JANUARY This publication is merely for information purposes.
This publication is merely for information purposes. TAXATION OF NON-RESIDENTS (Non-resident Income Tax) INCOME ACCRUED FROM 1 JANUARY 2011 TAX Agency MINISTRY OF THE FINANCE AND CIVIL SERVICE V.10 4 April
Global Tax Webcast. Taxation of the Digital Economy: an Asia Pacific perspective on the recent developments. KPMG Asia Pacific Tax Centre
Global Tax Webcast Taxation of the Digital Economy: an Asia Pacific perspective on the recent developments KPMG Asia Pacific Tax Centre May 15, 2018 Speakers Grant Wardell-Johnson, Leader, Australian Tax
Taxation of Permanent Establishment
Taxation of Permanent Establishment Permanent Establishment or PE is an important concept under Tax treaties. Multi National Corporations & Non- Residents carrying on Business is another country are liable
Business sets out key principles for digital tax measures
Media Release Business sets out key principles for digital tax measures Paris, 21 st January 2019 Business at OECD has released a list of eleven principles for designing digital tax measures. At this crucial
Libero Istituto Universitario Carlo Cattaneo International Tax Law a.a.2017/2018
Libero Istituto Universitario Carlo Cattaneo International Tax Law a.a.2017/2018 Permanent establishments Prof. Marco Cerrato Permanent establishment International legal framework The 1923 Report of the
TAXATION OF NON -RESIDENTS. (Non-resident Income Tax) INCOME ACCRUED FROM 1 JANUARY This publication is merely for information purposes. V.
This publication is merely for information purposes. TAXATION OF NON -RESIDENTS (Non-resident Income Tax) INCOME ACCRUED FROM 1 JANUARY 2011 Tax Agency V.5 MINISTRY OF ECONOMY AND FINANCE 17 January 2013
Optimizing Asian Operations Through Hong Kong s Double Tax Agreement Network
Volume 61, Number 11 March 14, 2011 Optimizing Asian Operations Through s Double Tax Agreement Network by Paul Previtera, Brandon Boyle, and Michael Kent Reprinted from Tax Notes Int l, March 14, 2011,
Cyprus Italy Tax Treaties
Cyprus Italy Tax Treaties AGREEMENT OF 24 TH APRIL, 1974 AS AMENDED BY PROTOCOL OF 7 TH OCTOBER, 1980 This is a Convention between Cyprus and Italy for the avoidance of double taxation and the prevention
The Advantages of the Cyprus Tax System
The Advantages of the Cyprus Tax System Nicos S. Kyriakides Partner in Charge, Limassol Copenhagen April 2009 Cyprus Tax Reform Objectives Conformity to European Law and the Acquis Communautaire on Direct
Doing business in Chad
Paris, France February 2015 Contents Legal framework Oil services companies Recent legislative developments Taxation of upstream companies Regulatory approvals Page 2 Chad is located in Central Africa
TAX CONSEQUENCES FOR CANADIANS DOING BUSINESS IN THE U.S.
TAX CONSEQUENCES FOR CANADIANS DOING BUSINESS IN THE U.S. Has your Canadian business expanded into the U.S.? Do you have dealings with U.S. customers? If so, have you considered the U.S. tax implications?
COMMISSION RECOMMENDATION. of relating to the corporate taxation of a significant digital presence
EUROPEAN COMMISSION Brussels, 21.3.2018 C(2018) 1650 final COMMISSION RECOMMENDATION of 21.3.2018 relating to the corporate taxation of a significant digital presence EN EN COMMISSION RECOMMENDATION of
continued on page 14 BY OLIVER FELSENSTEIN AND CHRISTOPH KUEPPERS (LOVELLS) continued on page 2
Practical European Tax Strategies WorldTrade Executive, Inc. The International Business Information Source TM REPORT ON TAX PLANNING FOR INTERNATIONAL COMPANIES OPERATING IN EUROPE Belgium Renovates and
London, 25 September Taxation of the Digital Economy
5 th Floor, 1 Angel Court London EC2R 7HJ United Kingdom + 44 7725 350 259 www.ibfed.org London, 25 September 2018 Taxation of the Digital Economy This paper considers the recent consultation on the taxation
THE TAX TREATY TREATMENT OF SERVICES: PROPOSED COMMENTARY CHANGES Public discussion draft 8 December 2006
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT THE TAX TREATY TREATMENT OF SERVICES: PROPOSED COMMENTARY CHANGES Public discussion draft 8 December 2006 CENTRE FOR TAX POLICY AND ADMINISTRATION
Future of tax in a digital economy: Are you prepared? The Dbriefs International Tax series
Future of tax in a digital economy: Are you prepared? The Dbriefs International Tax series Claudio Cimetta / Li Qun Gao / William Marshall 1 June 2017 Agenda The digital economy Tax challenges of the digital
Short Term Measures The EU Digital Services Tax (DST) Proposal v. The Indian Equalisation Levy
Short Term Measures The EU Digital Services Tax (DST) Proposal v. The Indian Equalisation Levy Sriram Govind, LL.M. Foundation for International Taxation International Taxation Conference, 2018 December
Introduction to International Payroll and Reporting. December 13, 2017
Introduction to International Payroll and Reporting December 13, 2017 Instructions Dialing instructions will appear once you connect on the web. 15 minute Q & A at end of session. Use the chat feature
Tax Issues related to the Digitalization of the Economy: Report
Distr.: General 5 April 2019 Original: English Committee of Experts on International Cooperation in Tax Matters Eighteenth session New York, 23-26 April 2019 Item 3 (j) of the provisional agenda Tax Issues
Taxation & the Digital Economy
Taxation & the Digital Economy John Muiruri - Partner Muiruri Macharia & Associates Email : jmuiruri@muirurimacharia.com Digital Economy Key Terms BEPS : Base Erosion & Profit Shifting (BEPS) is the result
THE TAXATION INSTITUTE OF HONG KONG CTA QUALIFYING EXAMINATION PILOT PAPER PAPER 3 INTERNATIONAL TAX
THE TAXATION INSTITUTE OF HONG KONG CTA QUALIFYING EXAMINATION PILOT PAPER PAPER 3 INTERNATIONAL TAX NOTE This Examination paper will contain SIX questions and candidates are expected to answers any FOUR
Engaging title in Green Descriptive element in Blue 2 lines if needed
BEPS Impact on TMT Sector January 2016 Engaging title in Green Descriptive element in Blue 2 lines if needed Second line optional lorem ipsum B Subhead lorem ipsum, date quatueriure Let s be crystal clear:
Tax Treatment of Digital Goods and Services: Overview and Cross-State Comparison
Tax Treatment of Digital Goods and Services: Overview and Cross-State Comparison Arizona State Legislature Ad Hoc Joint Committee on the Tax Treatment of Digital Goods and Services July 31, 2017 Taxation
Cyprus South Africa Tax Treaties
Cyprus South Africa Tax Treaties AGREEMENT OF 26 TH NOVEMBER, 1997 This is the Agreement between the Government of the Republic of Cyprus and the Government of the Republic of South Africa for the avoidance
1968 Income Tax Convention
1968 Income Tax Convention Treaty Partners: Uganda; Zambia Signed: August 24, 1968 Effective: In Uganda, from January 1, 1964. In Zambia, from April 1, 1964. See Article XX. Status: In Force CONVENTION
IMPORTANT INFORMATION FOR THE LIVE PROGRAM
Mastering U.S. Permanent Establishment Tax Under New OECD Guidance vs. General Tax Treaty Approach Navigating Income Attribution Rules in the U.S. Model Income Tax Convention and Recently Signed Tax Treaties
DOUBLE TAX TREATIES: COMPANIES ICAZ TAX SEMINAR. Presented by M. NGORIMA 22 February 2018
DOUBLE TAX TREATIES: COMPANIES ICAZ TAX SEMINAR Presented by M. NGORIMA 22 February 2018 DISCUSSION POINTS 1. What are double tax treaties? 2. Model Treaties 3. OECD Model Treaty Basic template 4. Model
VAT and the Digital Economy
VAT and the Digital Economy Overview of Policy Donato Raponi General Context Digital Single Market Strategy one of the Top 10 objectives of the Juncker Commission. VAT identified by business as one of
FOREWORD. Cyprus. Services provided by member firms include:
216/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
TECHNICAL EXPLANATION OF THE UNITED STATES-JAPAN INCOME TAX CONVENTION GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 JANUARY 1973 TABLE OF ARTICLES
TECHNICAL EXPLANATION OF THE UNITED STATES-JAPAN INCOME TAX CONVENTION GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 JANUARY 1973 It is the practice of the Treasury Department to prepare for the use of the
Analysis: Denmark Singapore Income Treaty Signed: Entry into force: Effective date:
Analysis: Denmark Singapore Income Treaty Type of treaty: Income Based on the OECD Model Treaty Signed: July 3, 2000 Entry into force: December 21, 2000 Effective date: In Denmark, from income year 2001;
Nigeria ratifies double tax agreement with Spain
27 February 2018 Global Tax Alert Nigeria ratifies double tax agreement with Spain EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
CHAPTER 3 DOUBLE TAX TREATIES
CHAPTER 3 DOUBLE TAX TREATIES This chapter looks in detail at the provisions contained in the OECD model convention. The following main areas are covered: definitions; exemption and credit relief. 3.1
Taxation of digital economy: does it require a fundamental change of approach?
Taxation of digital economy: does it require a fundamental change of approach? Pere M. Pons Dublin (Ireland), 19 September 2014 Disclaimer This presentation is a brief summary of the article Taxation of
The OECD s 3 Major Tax Initiatives
The OECD s 3 Major Tax Initiatives 1. The Global Forum on Transparency and Exchange of Information for Tax Purposes Peer review of ~ 100 countries International standard for transparency and exchange of
GST guidelines for recipients of imported services
GST guidelines for recipients of imported services October 2004 Prepared by the Policy Advice Division of the Inland Revenue Department Published October 2004 by the Policy Advice Division of the Inland
Double Taxation Avoidance Agreement between Philippines and Italy. Completed on December 8, 1980
Double Taxation Avoidance Agreement between Philippines and Italy Completed on December 8, 1980 This document was downloaded from (www.sas-ph.com).,,, CONVENTION BETWEEN THE REPUBLIC OF THE PHILIPPINES
Permanent establishments risk in Africa
Permanent establishments risk in Africa EY Africa Tax Conference September 2014 Panel Moderator Charles Makola International Tax EY South Africa Panel Justin Liebenberg International Tax EY South Africa
European Commission releases package on taxation of the digital economy
European Commission releases package on taxation of the digital economy On March 21, 2018, the European Commission issued a package on a Fair and Effective Tax System in the EU for the Digital Single Market,
INDIA BUDGET I. Equalisation levy stems out of OECD s BEPS Action Plan 1 on Digital Economy
INDIA BUDGET 2016 A. International tax I. Equalisation levy stems out of OECD s BEPS Action Plan 1 on Digital Economy New Chapter titled Equalisation Levy introduced in Finance Bill, considering it is
Observations on OECD Interim Paper and EU Commission Digital Tax Proposals
Observations on OECD Interim Paper and EU Commission Digital Tax Proposals KPMG International April 2018 Introduction On 16 March the OECD released its Report Tax Challenges Arising from Digitalization
Poland - Sri Lanka Income and Capital Tax Treaty (1980)
Page 1 of 9 Poland - Sri Lanka Income and Capital Tax Treaty (1980) Status: In Force Conclusion Date: 25 April 1980. Entry into Force: 21 October 1983. Effective Date: 1 January 1983 (see Article 24).
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings Page 1 of 21 Table of Contents 1. Introduction...3 2. Overview of Council Directive (EU)
SIFY TECHNOLOGIES LIMITED NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS (In thousands of Rupees, except share data and as stated otherwise)
1. Reporting entity SIFY TECHNOLOGIES LIMITED NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS (In thousands of Rupees, except share data and as stated otherwise) Sify Technologies Limited, ( Sify or the
TREATY SERIES 2007 Nº 21
TREATY SERIES 2007 Nº 21 Convention Between the Government of Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
Digital Economy Taxation
OECD Publishes Report on Taxation of the Digital Economy; European Commission Publishes Draft Directives SUMMARY While the OECD has published a report on the taxation of the digital economy, noting that
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES
UK/KENYA DOUBLE TAXATION AGREEMENT SIGNED 31 JULY 1973 Amended by a Protocol signed 20 January 1976 and notes dated 8 February 1977
UK/KENYA DOUBLE TAXATION AGREEMENT SIGNED 31 JULY 1973 Amended by a Protocol signed 20 January 1976 and notes dated 8 February 1977 Entered into force 30 September 1977 Effective in United Kingdom from
How State Nexus Rules Impact
How State Nexus Rules Impact You Monday, June 26, 2017 2:15-3:30pm Presented by: Jeffrey A. Ring, CPA, MST Principal BerryDunn 100 Middle Street Portland, ME 04101 P: 207.541.2318 E: jring@berrydunn.com
1980 Income and Capital Gains Tax Convention
1980 Income and Capital Gains Tax Convention Treaty Partners: Gambia; United Kingdom Signed: May 20, 1980 In Force: July 5, 1982 Effective: In Gambia, from January 1, 1980. In the U.K.: income tax and
Overview. Application of Art. 6 and 7 UN Model in the case of mining and oil/gas extraction. Definition of immovable property Art.
Overview Extractive Industries Taxation Issues Related to Tax Treaties Friday, 10 November 2017 (Session 2 Extractive Industries Taxation) Application of Art. 6 and 7 in the case of mining and oil / gas
Tangible Personal Property Goes Digital: State Tax Implications
Journal of Multistate Taxation and Incentives (Thomson Reuters/Tax & Accounting) Volume 27, Number 7, October 2017 SHOP TALK Tangible Personal Property Goes Digital: State Tax Implications JEFFREY S. REED
Discussion on amendments to Agency PE rules in Budget 2018
Discussion on amendments to Agency PE rules in Budget 2018 Jimit Devani July 2018 Agenda Concept of Permanent Establishment (PE) BEPS Action Plan 7 India budget update Consequence of PE Way forward Recent
Do we have the wrong tax system for the digital economy? Alf Capito, Tax Policy Leader, EY Asia Pacific July 2014
Do we have the wrong tax system for the digital economy? Alf Capito, Tax Policy Leader, EY Asia Pacific July 2014 Key features of the digital economy as seen by the OECD taskforce Mobility Reliance on
AFRICAN TAX ADMINISTRATION FORUM (ATAF)
AFRICAN TAX ADMINISTRATION FORUM (ATAF) Leading Africa in Tax Administration CROSS BORDER TAXATION IN AFRICA CHALLENGES AND ATAF S RESPONSE Dr. Nara Monkam: ATAF Director Research 4 th International Workshop
15445/17 AS/AR/mpd 1 DG G 2B
Council of the European Union Brussels, 5 December 2017 (OR. en) 15445/17 FISC 346 ECOFIN 1092 OUTCOME OF PROCEEDINGS From: General Secretariat of the Council To: Delegations No. prev. doc.: 15175/17 Subject:
CHALLENGES OF THE DIGITAL ECONOMY: AN OVERVIEW 1
Distr.: General 5 October 2017 Original: English Committee of Experts on International Cooperation in Tax Matters Fifteenth session Geneva, 17-20 October 2017 Agenda item 5(c)(ix) Tax consequences of the
Double Taxation Avoidance Agreement between Philippines and Spain. Completed on January 1, 1994
Double Taxation Avoidance Agreement between Philippines and Spain Completed on January 1, 1994 This document was downloaded from (www.sas-ph.com).,,, The Convention between the Republic of the Philippines
Transfer pricing in the Faroe Islands
Transfer pricing in the Faroe Islands This guide comprises a generalized description of the transfer pricing legislation in the Faroes. Further, it describes the obligation to disclose information on intercompany
WORLD SERVICES GROUP
WORLD SERVICES GROUP Latin American Regional Meeting E Commerce Taxation Aspects of Electronic Commerce Description Domestic Tax Implications International Tax Issues Conclusions in solving e-commerce
wts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries
wts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries Table of Contents Preface 3 Conclusions at a glance 4 Summary from the survey 5 Detailed
New Australia- Germany Tax Treaty enters into force
12 December 2016 Global Tax Alert New Australia- Germany Tax Treaty enters into force EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
Spain releases draft bill on Digital Services Tax
25 October 2018 Indirect Tax Alert Spain releases draft bill on Digital Services Tax NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
The European Commission Is Attempting a Radical Change to How Digital Transactions Are Taxed Throughout the EU
The European Commission Is Attempting a Radical Change to How Digital Transactions Are Taxed Throughout the EU October 20, 2017 On 21 September 2017, the European Commission issued a fact sheet outlining
Ireland update: Considerations for U.S. companies
Ireland update: June 20, 2013 Leading today s discussion Dan Gaffey Julian Caplin Michael Shelley Michael McGivern Partner Partner, Head of International Audit International Tax Partner Corporate Finance
Permanent Establishment in India: checking the rule
Permanent Establishment in India: checking the rule The India s Delhi High Court (HC) has recently ruled that outsourcing of services by US company to Indian affiliate does not constitute PE. It is aim
GREECE Agreement for avoidance of double taxation with Greece Whereas the annexed Agreement between the Government of India and the Government of
GREECE Agreement for avoidance of double taxation with Greece Whereas the annexed Agreement between the Government of India and the Government of Greece for the avoidance of double taxation of income has
Proposed ecommerce Tax Second draft of legislative proposals
9 February 2018 For Revenue Department Proposed ecommerce Tax Second draft of legislative proposals The Joint Foreign Chambers of Commerce in Thailand is the umbrella body for most foreign chambers of
Article 18 Pensions/ Social Security Payments/ Annuities
Article 18 Pensions/ Social Security Payments/ Annuities C.A. Divakar Vijayasarathy This paper is a copyright of Divakar Vijayasarathy & Associates. The author and the firm expressly disown their liability
Comparison and Assessment of the Tax Treatment of Foreign Source Income in Canada, Australia, France, Germany and the United States
Osgoode Hall Law School of York University Osgoode Digital Commons Commissioned Reports and Studies Faculty Scholarship 1996 Comparison and Assessment of the Tax Treatment of Foreign Source Income in Canada,
INDIA BUDGET
INDIA BUDGET 2018-19 Author Jairaj Purandare Tags Budget Business Connection Capital Gains India Investment Activity Tax Policy INTRODUCTION All eyes were set on the Indian Finance Minister on February
Pinsent Masons in Spain
Pinsent Masons in Spain Pinsent Masons in Spain Pinsent Masons is a sector focussed global law firm. Our strategy is to invest in geographies that connect our clients to where they want to do business.
General Definitions Permanent Establishment
CONVENTION BETWEEN SPAIN AND THE PEOPLE'S REPUBLIC OF BULGARIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL Prom. SG. 11/8 Feb 1991
Sharing may be caring, but is it also taxable?
Sharing may be caring, but is it also taxable? State Taxation of the Sharing Economy 23 rd Annual Paul J. Hartman State and Local Tax Forum Vanderbilt University Law School October 25-27, 2016 Agenda I.
THE KNOWLEDGE DEVELOPMENT BOX Public Consultation JANUARY 2015
THE KNOWLEDGE DEVELOPMENT BOX Public Consultation JANUARY 2015 Public Consultation Paper: The Knowledge Development Box Department of Finance January 2015 Tax Policy Division Department of Finance Government
Working Party on Tax Questions (Direct Taxation CCTB) Challenges of the digital economy for direct taxation - State of play and the way forward
Brussels, 11 October 2017 WK 11067/2017 INIT LIMITE FISC ECOFIN MEETING DOCUMENT From: To: Subject: Presidency Working Party on Tax Questions (Direct Taxation CCTB) Challenges of the digital economy for
Fair taxation of the digital European Commission DG TAXUD. economy
Fair taxation of the digital European Commission DG TAXUD economy The issue at stake Difficulty to tax/ opportunities for tax avoidance Lack of a level playing field and distortion of competition Less
FUTURE TAXATION OF COMPANY PROFITS
FUTURE TAXATION OF COMPANY PROFITS What to do with intangibles? Presentation at Taxation of the digitalised economy: analysing the OECD approach event 19-02-2019 WHAT IS BEING PROPOSED? SMALL INNOVATIVE
OIL & GAS SECTOR KENYA GUIDE BOTSWANA ETHIOPIA KENYA MADAGASCAR MALAWI MAURITIUS NIGERIA RWANDA SUDAN TANZANIA UGANDA ZAMBIA
OIL & GAS SECTOR BOTSWANA ETHIOPIA KENYA MADAGASCAR MALAWI MAURITIUS NIGERIA RWANDA SUDAN TANZANIA UGANDA ZAMBIA KENYA GUIDE Anjarwalla & Khanna ALN Overview A&K is the largest corporate law firm in East
GOVERNMENT NOTICE SOUTH AFRICAN REVENUE SERVICE INCOME TAX ACT, 1962
GOVERNMENT NOTICE SOUTH AFRICAN REVENUE SERVICE No. 391 18 May 2007 INCOME TAX ACT, 1962 CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE REPUBLIC OF GHANA FOR
Nairobi GMT +3. EY +254 (20) Mail address: Fax: +254 (20)
Kenya 717 ey.com/globaltaxguides ey.com/taxguidesapp Nairobi GMT +3 EY +254 (20) 271-5300 Mail address: Fax: +254 (20) 271-6271 P.O. Box 44286 00100 Email: info@ey.co.ke Nairobi GPO Kenya Street address:
1977 Income Tax Convention and Final Protocol
1977 Income Tax Convention and Final Protocol Treaty Partners: Netherlands; Zambia Signed: December 19, 1977 In Force: November 9, 1982 Effective: In the Netherlands, from January 1, 1983. In Zambia, from
Australian Treasury Discussion Paper on the digital economy and Australia s corporate tax system: A detailed review
4 October 2018 Global Tax Alert Australian Treasury Discussion Paper on the digital economy and Australia s corporate tax system: A detailed review NEW! EY Tax News Update: Global Edition EY s new Tax
Outline TAXATION AND DIGITALIZATION OF THE ECONOMY, AND THE TAXATION OF ODA-FUNDED PROJECTS
T TAXATION AND DIGITALIZATION OF THE ECONOMY, AND THE TAXATION OF ODA-FUNDED PROJECTS PROTOCOL HIS EXCELLENCY Mr. Mahmadamin Mahmadaminov (Vice-President of the Economic and Social Council(ECOSOC). Mr.
This Convention shall apply to persons who are residents of one or both of the States.
South Africa Convention between the government of the Kingdom of the Netherlands and the government of the Republic of South Africa for the avoidance of double taxation and the prevention of fiscal evasion
AGREEMENT OF 28 TH MAY, Moldova
AGREEMENT OF 28 TH MAY, 2009 Moldova CONVENTION BETWEEN IRELAND AND THE REPUBLIC OF MOLDOVA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Ireland
Foundation for International Taxation
Foundation for International Taxation 9 th December, 2017 Brief Presentation on A better & complete system of E-commerce Taxation CA Rashmin Sanghvi www.rashminsanghvi.com Important Notes: 1. This presentation
Stakeholder Consultation: Review of Double Taxation Treaties 2018
Ref: IT 30 November 2018 David Price Tax Treaty Team BAI International Relations and Capacity Building Zone C, Floor 9 10 South Colonnade Canary Wharf E14 4PU Via email: taxtreaty.team@hmrc.gsi.gov.uk