Hong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with Latvia. 21 April Issue No. 7
|
|
- Cameron Scott
- 6 years ago
- Views:
Transcription
1 Hong Kong Tax Alert 21 April Issue No. 7 Hong Kong signs comprehensive double tax agreement with Latvia On 13 April 2016, Hong Kong signed a comprehensive avoidance of double taxation agreement (CDTA) with Latvia. This brings the number of CDTAs Hong Kong has concluded with other jurisdictions to thirtyfive. The CDTA with Latvia contains several favorable provisions which are expected to facilitate closer economic and trade ties between Hong Kong and Latvia. This alert summarizes the salient points of the provisions of the CDTA as applicable to Hong Kong residents. Appendix I to this alert summarizes the status of Hong Kong s current CDTA network and CDTAs currently under negotiation or pending ratification.
2 Who is covered by the CDTA The CDTA only applies to persons who are residents of either Hong Kong or Latvia. In this regard, a company that is incorporated or constituted under the laws of Hong Kong automatically qualifies as a Hong Kong resident. A company which is not so incorporated or constituted, would be regarded as a Hong Kong resident only if it is normally managed or controlled in Hong Kong, a residence test commonly used in other CDTAs Hong Kong has concluded. Taxpayers may require a Hong Kong certificate of residence To enjoy the preferential tax treatments in Latvia detailed below, the tax authority of Latvia may require that a Hong Kong tax resident produce a certificate of residence (CoR) issued by the Inland Revenue Department (IRD) confirming that the taxpayer is a Hong Kong tax resident. In processing an application for a CoR, the IRD may, in addition to the residence test, consider whether the applicant is the beneficial owner of the income concerned. Where the applicant has little or no business substance in Hong Kong, the IRD may also consider whether the taxpayer may be abusing the terms of a CDTA. As such, regardless of whether a company is incorporated or constituted under the laws of Hong Kong, it should not be assumed that said company will automatically be granted a CoR. Tax benefits available to Hong Kong residents under the CDTA Business profits Active business profits of a Hong Kong resident enterprise will not be liable to tax in Latvia unless they are attributable to a permanent establishment (PE) maintained by the Hong Kong enterprise in Latvia. Where a Hong Kong enterprise has maintained a PE in Latvia, only profits attributable to the PE will be liable to tax in Latvia. A building site or construction, assembly or installation project or supervisory activities in connection therewith, of a Hong Kong resident enterprise will only constitute a PE in Latvia if such site, project or activities last more than nine months (this is shorter than the twelve months period provided under the OECD Model). The furnishing of services, including consultancy services, by a Hong Kong resident enterprise through employees or other personnel engaged for such purpose will only constitute a PE in Latvia if the services continue (for the same or a connected project) for a period or periods exceeding in the aggregate six months within any twelve month period. The Protocol to the CDTA further provides that a Hong Kong resident enterprise engaged in offshore activities in connection with the exploration or extraction from the sea bed and sub-soil of natural resources situated in Latvia will only be deemed to have a PE in Latvia if it carries on such activities in Latvia for a period or periods exceeding in the aggregate thirty days in any twelve month period. A Hong Kong resident enterprise will not be liable to tax in Latvia if it simply maintains a buying office in Latvia which only makes purchases for the Hong Kong resident enterprise. Hong Kong resident airliners and ship owners will not be subject to tax in Latvia in respect of profits derived from international traffic. However, income of a Hong Kong resident airliner so exempt from taxation in Latvia under the CDTA will be charged to tax in Hong Kong under the relevant provisions of the Hong Kong tax code. The above treatments will apply in a reciprocal manner to Latvian residents deriving active business profits in Hong Kong. 2
3 Exemption or reduction of tax on dividends, interest, royalties and capital gains on disposal of shares Subject to specific anti-avoidance provisions, the below table summarizes the applicable withholding rates for the captioned income flows received from Latvia by a Hong Kong resident as beneficial owner. Tax rate Passive income Normal withholding rate Reduced rate under the CDTA Notes Dividends Interest Royalties Capital gains on disposal of shares 0/15/30% 1 0/5/15% 1 0/15% 1 0/2% 5 0/10% 2 0/10% 3 0/3% 4 0/2% 6 1. No withholding tax is imposed on dividends, interest and royalties paid by Latvian entities, except for such income paid to a resident of a state or territory that has been recognized as a low-tax or notax state or territory under the domestic tax law of Latvia. Various rates apply to such payments. 2. A 0% rate applies if the beneficial owner of the dividend is a company (other than a partnership), the Hong Kong government, the Hong Kong Monetary Authority, the Exchange Fund, any institution wholly or mainly owned by the Hong Kong government as may be agreed from time to time between the competent authorities of the contracting parties, or a pension fund or scheme. For all other cases, a 10% rate applies. 3. A 0% rate applies if the beneficial owner of the interest is a company (other than a partnership), the Hong Kong government, the Hong Kong Monetary Authority, the Exchange Fund, any institution wholly or mainly owned by the Hong Kong government as may be agreed from time to time between the competent authorities of the contracting parties, or a pension fund or scheme. For all other cases, a 10% rate applies. 4. A 0% rate applies if the beneficial owner of the royalties is a company (other than a partnership). For all other cases, a 3% rate applies. 5. Under the current domestic tax law in Latvia, gains on the disposal of shares in a Latvian company whose assets do not comprise substantially real estate in Latvia are not subject to tax in Latvia. A 2% withholding tax rate is however imposed on proceeds received from the sale of shares of a company, if in the year of the sale or in the preceding year, 50% or more of the company s assets directly or indirectly consist of real estate located in Latvia. 6. Under the CDTA, capital gains on the disposal of shares in a Latvian company derived by a Hong Kong resident investor will generally be exempt from tax in Latvia. The major exception to this is when the shares being disposed of are in respect of a company holding substantial immovable property located in Latvia. This exception will not apply however if certain conditions are met. Avoidance of double taxation Where the income of a Hong Kong resident is subject to tax in both Hong Kong and Latvia, the Hong Kong resident can credit the tax paid in Latvia on the relevant income against the Hong Kong tax liability arising on the same income. The available tax credit is, however, limited to the Hong Kong tax charged on the same income. Exchange of Information (EoI) In addition to the direct taxes covered by the CDTA, Article 4 of the Protocol to the CDTA provides that the EoI provision shall also apply to value added tax and immovable property tax administered and effective in Latvia. Effective date of the CDTA The CDTA will only come into force in the tax year following the calendar year in which the relevant ratification procedures are completed. Assuming that the ratification procedures can be completed in 2016, the CDTA shall then have effect as follows: (a) in Hong Kong: for any year of assessment beginning on or after 1 April 2017; (b) in Latvia: for any tax period beginning on or after 1 January
4 Appendix I Latest status of the Hong Kong s CDTA network 31 CDTAs signed and ratified Country / jurisdiction Effective in Hong Kong from the year of assessment Effective in the other contracting party from the year of assessment 1. Austria 2012/13 1 January Belgium 2004/05 1 January Brunei 2011/12 1 January Canada 2014/15 1 January Czech Republic 2013/14 1 January France 2012/13 1 January Guernsey 2014/15 1 January Hungary 2012/13 1 January Indonesia 2013/14 1 January Ireland 2012/13 1 January Italy 2016/17 1 January Japan 2012/13 1 January Jersey 2014/15 1 January Kuwait 2014/15 1 January Liechtenstein 2012/13 1 January Luxembourg 2008/09 1 January Mainland China 2007/08 1 January Malaysia 2013/14 1 January Malta 2013/14 1 January Mexico 2014/15 1 January Netherlands 2012/13 1 January New Zealand 2012/13 1 April Portugal 2013/14 1 January Qatar 2014/15 1 January South Africa 2016/17 1 January Spain 2013/14 1 April Switzerland 2013/14 1 January Thailand 2006/07 1 January United Kingdom 2011/12 1 or 6 April United Arab Emirates 2016/17 1 January Vietnam 2010/11 1 January CDTAs - signed but pending ratification Korea, Latvia, Romania and Russian Federation 12 CDTAs under negotiation Bahrain, Bangladesh, Cyprus, Finland, Germany, India, Israel, Macau SAR, Macedonia, Mauritius, Pakistan and Saudi Arabia 4
5 Financial Services Hong Kong office Ian McNeill Managing, Tax, Asia-Pacific Principal tax contact, Ernst & Young Tax Services Limited Florence Chan Business Tax Services Paul Ho Napson Hon Executive Director Sunny Liu Executive Director International Tax Services James Badenach John Praides Adam Williams Transfer Pricing Services Justin Kyte Jonathan Thompson EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com Ernst & Young Tax Services Limited. All Rights Reserved. APAC No ED None. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice. ey.com/china
Hong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with Latvia. 21 April Issue No. 7
Hong Kong Tax Alert 21 April 2016 2016 Issue No. 7 Hong Kong signs comprehensive double tax agreement with Latvia On 13 April 2016, Hong Kong signed a comprehensive avoidance of double taxation agreement
More informationHong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with Romania. Who is covered by the CDTA. 27 November Issue No.
Hong Kong Tax Alert 27 November 2015 2015 Issue No. 19 Hong Kong signs comprehensive double tax agreement with Romania On 18 November 2015, Hong Kong signed a comprehensive avoidance of double taxation
More informationHong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with Saudi Arabia. 31 August Issue No. 13
Hong Kong Tax Alert 31 August 2017 2017 Issue No. 13 Hong Kong signs comprehensive double tax agreement with Saudi Arabia On 24 August 2017, Hong Kong signed a comprehensive avoidance of double taxation
More informationHong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with the Russian Federation. Who is covered by the CDTA
Hong Kong Tax Alert 29 January 2016 2016 Issue No. 2 Hong Kong signs comprehensive double tax agreement with the Russian Federation On 18 January 2016, Hong Kong signed a comprehensive avoidance of double
More informationHong Kong Tax Alert. Hong Kong signs comprehensive double tax agreement with India. Who is covered by the CDTA law. 4 April Issue No.
Hong Kong Tax Alert 4 April 2018 2018 Issue No. 9 Hong Kong signs comprehensive double tax agreement with India On 19 March 2018, Hong Kong signed a comprehensive avoidance of double taxation agreement
More informationHong Kong. The 2016/17 budget. Profits tax. Salaries tax
Hong Kong The 2016/17 budget The Financial Secretary delivered the 2016/17 budget on 24 February 2016. The tax and one-off relief measures proposed in the budget are summarised below. Profits tax The profits
More informationInternational Tax Conference
International Tax Conference Hong Kong s Experience with its International Tax Treaty Network Richard Wong Commissioner of Inland Revenue 19 June 2014 1 Introduction Purpose of signing a tax treaty Fairness
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationKey Hong Kong Tax Develop ments. 27 February 2017
Key Hong Kong Tax Develop ments 27 February 2017 Agenda A Key Hong Kong Tax Developments 1) Base Erosion and Profit Shifting 2) Corporate Treasury Centre 3) Offshore Private Equity Fund Exemption 4) Comprehensive
More informationIreland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
17 July 2017 Global Tax Alert Ireland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationFrance and Singapore sign revised income tax treaty
23 January 2015 International Tax Alert News from the Global Tax Desk Network EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationTaxation on Hong Kong shipping companies, vessels and goods, and potential reforms
Taxation on Hong Kong shipping companies, vessels and goods, and potential reforms Hong Kong Tax System Simple, transparent, straightforward Territorial source principle Hong Kong has: Profits tax, salaries
More informationHong Kong Tax alert. Views of stakeholders sought on proposed automatic exchange of financial account information
4 May 2015 2015 Issue No. 8 Hong Kong Tax alert Views of stakeholders sought on proposed automatic exchange of financial account information As a responsible member of the international community, the
More informationTax Newsflash January 31, 2014
Tax Newsflash January 31, 2014 Luxembourg s New Double Tax Treaties As of 1 January 2014, Luxembourg further enlarged its double tax treaty network with the entry into force of the new double tax treaties
More information17 March Issue No. 6
Hong Kong Tax Alert 17 March 2017 2017 Issue No. 6 Hong Kong introduces legislative bill to attract offshore aircraft leasing and aircraft leasing management businesses to Hong Kong Last Friday, the Inland
More informationEurope-Hong Kong Tax Treaties (Articles 1 13)
Europe-Hong Kong Tax Treaties (Articles 1 13) Oliver-Christoph Günther/ Na LI June 19, 2014 Institute for Austrian and International Tax Law www.wu.ac.at/taxlaw 1 Agenda Overview and structure Personal
More informationReal Estate & Private Equity workshop
Real Estate & Private Equity workshop Moderator: Panelists: Joseph Hendry, Managing Director, Brown Brothers Harriman Gautier Despret, Senior Manager, Ernst & Young Patrick Goebel, Counsel, Allen & Overy
More informationHong Kong joins Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
14 August 2017 Global Tax Alert Hong Kong joins Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY
More informationGuide to Treatment of Withholding Tax Rates. January 2018
Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep
More information7 November Issue No. 14
Hong Kong Tax Alert 7 November 2017 2017 Issue No. 14 The IRD clarifies how it will interpret and administer the concessionary tax regime for qualifying aircraft leasing activities On 27 October 2017,
More informationCyprus signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
25 July 2017 Global Tax Alert Cyprus signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationWithholding Tax Rate under DTAA
Withholding Tax Rate under DTAA Country Albania 10% 10% 10% 10% Armenia 10% Australia 15% 15% 10%/15% [Note 2] 10%/15% [Note 2] Austria 10% Bangladesh Belarus a) 10% (if at least 10% of recipient company);
More informationThe Czech Republic signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
19 July 2017 Global Tax Alert The Czech Republic signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of
More informationHong Kong Tax Alert. Legislative proposal to grant profits tax exemption to resident, privately-offered open-ended fund companies
Hong Kong Tax Alert 5 July 2017 2017 Issue No. 12 Legislative proposal to grant profits tax exemption to resident, privately-offered open-ended fund companies Last Wednesday, the Government introduced
More informationInvesting In and Through Singapore
Investing In and Through Singapore Shanker Iyer 17 May 2012 Contents Benefits of Singapore Setting Up and Ongoing Requirements Territorial Tax System Taxation of Passive Income and Other income Tax Incentives
More informationTable of Contents. 1 created by
Table of Contents Overview... 2 Exemption Application Instructions for U.S. Tax Residents Living in the U.S.... 3 Exemption Application Instructions for Tax Residents of European Union Member States (other
More informationSINGAPORE - FINAL LIST OF MFN EXEMPTIONS (For the Second Package of Commitments) Countries to which the measure applies
All Sectors: Presence of: - unskilled and semi-skilled natural persons - skilled persons (include craftsmen skilled in a particular trade, but exclude specialists/professio nal personnel at management
More informationWithholding tax rates 2016 as per Finance Act 2016
Withholding tax rates 2016 as per Finance Act 2016 Sr No Country Dividend Interest Royalty Fee for Technical (not being covered under Section 115-O) Services 1 Albania 10% 10% 10% 10% 2 Armenia 10% 10%
More information3 January Issue No. 1. Court-free amalgamation - utilization of pre-amalgamation tax losses subject to strict restrictions post amalgamation
Hong Kong Tax Alert 3 January 2017 2017 Issue No. 1 Court-free amalgamation - utilization of pre-amalgamation tax losses subject to strict restrictions post amalgamation A potentially contentious and complicated
More informationThe Capital Requirements (Country-by-Country Reporting) Regulations December 2017
HSBC Holdings plc The Capital Requirements (Country-by-Country Reporting) Regulations 2013 31 December 2017 This report has been prepared for HSBC Holdings plc and its subsidiaries (the HSBC Group ) to
More informationComperative DTTs of Pakistan
Comperative DTTs of Pakistan 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 S. No. COUNTRY CONTINENT Republic/Dem ocratic/kingdo m/sultanate P.E. BUSINESS PROFIT SHIPPING AIR TRANSPORT DIVIDEND INTEREST ROYALITIES
More informationAlbania 10% 10%[Note1] 10% 10% Armenia 10% 10% [Note1] 10% 10% Austria 10% 10% [Note1] 10% 10%
Country Dividend (not being covered under Section 115-O) Withholding tax rates Interest Royalty Fee for Technical Services Albania 10% 10%[Note1] 10% 10% Armenia 10% Australia 15% 15% 10%/15% 10%/15% Austria
More informationDouble tax considerations on certain personal retirement scheme benefits
www.pwc.com/mt The elimination of double taxation on benefits paid out of certain Maltese personal retirement schemes February 2016 Double tax considerations on certain personal retirement scheme benefits
More informationReporting practices for domestic and total debt securities
Last updated: 27 November 2017 Reporting practices for domestic and total debt securities While the BIS debt securities statistics are in principle harmonised with the recommendations in the Handbook on
More informationAustria Country Profile
Austria Country Profile EU Tax Centre March 2014 Key tax factors for efficient cross-border business and investment involving Austria EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationejournal of Tax Research
ejournal of Tax Research Volume 9, Number 3 December 2011 (Special Edition: Double Tax Agreements in the Asia Pacific) CONTENTS 245 Editorial Nolan Cormac Sharkey and Kathrin Bain 247 Jefferson Vanderwolk
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Australia Austria
More informationCurrent Issues in International Tax Policy
Current Issues in International Tax Policy Shigeto HIKI Director, International Tax Policy Division, Tax Bureau, Ministry of Finance, Japan The Fourth IMF-Japan High-Level Tax Conference For Asian Countries
More informationHong Kong. Tax Alert. Hong Kong
Hong Kong Tax Alert 10 December 2015 2015 Issue No. 20 Hong Kong introduces a legislative bill for enhancing its attractiveness as a corporate treasury centre to multinational corporations The bill 1 seeks
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationIRS Reporting Rules. Reference Guide. serving the people who serve the world
IRS Reporting Rules Reference Guide serving the people who serve the world The United States has and continues to maintain a policy of not taxing the deposit interest earned by United States (US) nonresidents
More informationAUTOMATIC EXCHANGE OF INFORMATION (AEOI)
AUTOMATIC EXCHANGE OF INFORMATION (AEOI) As the world becomes increasingly globalised, money can be transferred from one jurisdiction to another with ease. While this may help to facilitate trade and boost
More informationFATCA, an American law applied starting July 1 st, 2014 to fight offshore tax evasion by US Taxpayers
Communication on June 19 th 2014 last update: July 23 rd 2018 FATCA, an American law applied starting July 1 st, 2014 to fight offshore tax evasion by US Taxpayers Goal and legal framework of FATCA The
More informationWhen will CbC reports need to be filled?
Who will be subject to CbCR? Country by Country Reporting (CbCR) applies to multinational companies (MNCs) with a combined revenue of euros 750 million or more When will CbC reports need to be filled?
More informationTAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015
Arrangement TAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015 Arrangement Regulation 1 Interpretation... 3 2 Meaning of relevant date and relevant
More informationCountries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012
Countries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012 This table shows the maximum rates of tax those countries with a Double Taxation Agreement
More informationArgentina Bahamas Barbados Bermuda Bolivia Brazil British Virgin Islands Canada Cayman Islands Chile
Americas Argentina (Banking and finance; Capital markets: Debt; Capital markets: Equity; M&A; Project Bahamas (Financial and corporate) Barbados (Financial and corporate) Bermuda (Financial and corporate)
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Andorra Australia
More informationMalta s Double Tax Treaties
Malta s Double Tax Treaties November 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax
More information3 March Issue No. 5
Hong Kong Tax Alert 3 March 2017 2017 Issue No. 5 Basel III compliant banking regulatory capital securities (RCSs) IRD states its interpretation of the tax treatment of RCSs Last week, the Inland Revenue
More informationHong Kong SAR Tax Profile
o Hong Kong SAR Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: July 2016 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation
More informationLuxembourg Country Profile
Luxembourg Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Luxembourg EU Member State Yes Double Tax Treaties With: Albania (a) Andorra
More informationKey Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents. 18 July 2014
Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents 18 July 2014 How do we tax non-residents on capital income? Domestic design issues Tax treaty issues Interrelationship between
More informationOther Tax Rates. Non-Resident Withholding Tax Rates for Treaty Countries 1
Other Tax Rates Non-Resident Withholding Tax Rates for Treaty Countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15
More informationFATCA Update May 2014
www.pwc.com The Basics Foreign Account Tax Compliance Act Purpose of Prevent and detect offshore tax evasion by US citizens Increased information reporting Enforced by withholding tax Effective begins
More informationPENTA CLO 2 B.V. (the "Issuer")
THIS NOTICE CONTAINS IMPORTANT INFORMATION OF INTEREST TO THE REGISTERED AND BENEFICIAL OWNERS OF THE NOTES (AS DEFINED BELOW). IF APPLICABLE, ALL DEPOSITARIES, CUSTODIANS AND OTHER INTERMEDIARIES RECEIVING
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Czech Rep. EU Member State Yes Double Tax With: Treaties Albania Armenia
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationH S B C H O L D I N G S P L C HSBC HOLDINGS PLC THE CAPITAL REQUIREMENTS. (Country-by-Country Reporting) REGULATION 2013
HSBC HOLDINGS PLC THE CAPITAL REQUIREMENTS (Country-by-Country Reporting) REGULATION 2013 31 December 2015 This report has been prepared for HSBC Holdings plc and its subsidiaries (the HSBC Group ) to
More information"Our purpose is client services which is supportive, responsive and focused on delivering results." Harneys Fiduciary
Hong Kong Companies Hong Kong is the economic and financial gateway to China. Over 1.2 million private limited companies have been registered with the Hong Kong Companies Registry. Hong Kong, as a global
More informationSection 872. Gross Income. Rev. Rul
Section 872. Gross Income (Also sections 883, 894.) 26 CFR 1.872 2: Exclusions from gross income of nonresident alien individuals. (Also 26 CFR 1.883 1.) This revenue ruling updates the list of countries
More informationCross Border Investments (inc. M&A) through Singapore
Cross Border Investments (inc. M&A) through Singapore Shanker Iyer 22 August 2015 SINGAPORE HONGKONG 20 YEARS IN PRACTICE AGENDA Non-Tax Issues Tax Issues SINGAPORE HONGKONG 20 YEARS IN PRACTICE NON-TAX
More informationEQUITY REPORTING & WITHHOLDING. Updated May 2016
EQUITY REPORTING & WITHHOLDING Updated May 2016 When you exercise stock options or have RSUs lapse, there may be tax implications in any country in which you worked for P&G during the period from the
More informationDefinition of international double taxation
Definition of international double taxation Juridical double taxation: imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties With: Albania Algeria Australia Austria
More informationAPA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
More informationRev. Proc Implementation of Nonresident Alien Deposit Interest Regulations
Rev. Proc. 2012-24 Implementation of Nonresident Alien Deposit Interest Regulations SECTION 1. PURPOSE Sections 1.6049-4(b)(5) and 1.6049-8 of the Income Tax Regulations, as revised by TD 9584, require
More informationActuarial Supply & Demand. By i.e. muhanna. i.e. muhanna Page 1 of
By i.e. muhanna i.e. muhanna Page 1 of 8 040506 Additional Perspectives Measuring actuarial supply and demand in terms of GDP is indeed a valid basis for setting the actuarial density of a country and
More informationCorrigendum. OECD Pensions Outlook 2012 DOI: ISBN (print) ISBN (PDF) OECD 2012
OECD Pensions Outlook 2012 DOI: http://dx.doi.org/9789264169401-en ISBN 978-92-64-16939-5 (print) ISBN 978-92-64-16940-1 (PDF) OECD 2012 Corrigendum Page 21: Figure 1.1. Average annual real net investment
More informationForeign Account Tax Compliance Act (FATCA)
Foreign Account Tax Compliance Act (FATCA) Andrea Garcia Castelao November 18, 2013 Foreign Account Tax Compliance Act (FATCA) 0 2013 Deloitte Tax LLP FATCA Update Final FATCA regulations were released
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationide: FRANCE Appendix A Countries with Double Taxation Agreement with France
Fiscal operational guide: FRANCE ide: FRANCE Appendix A Countries with Double Taxation Agreement with France Albania Algeria Argentina Armenia 2006 2006 From 1 March 1981 2002 1 1 1 All persons 1 Legal
More information(of 19 March 2013) Valid from 1 January A. Taxpayers
Leaflet. 29/460 of the Cantonal Tax Office on withholding taxes applicable to pension benefits under private law for persons without domicile or residence in Switzerland (of 19 March 2013) Valid from 1
More informationHong Kong SAR Tax Profile
o Hong Kong SAR Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation
More informationNon-resident withholding tax rates for treaty countries 1
Non-resident withholding tax rates for treaty countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15 15/25 Armenia
More informationThe Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
More informationKPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX
KPMG s Individual Income Tax and Social Security Rate Survey 2009 TAX B KPMG s Individual Income Tax and Social Security Rate Survey 2009 KPMG s Individual Income Tax and Social Security Rate Survey 2009
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2018 EU Tax Centre June 2018 Turkey Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties No
More informationMalta s Double Tax Treaties
Malta s Double Treaties February 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties
More informationSTOXX EMERGING MARKETS INDICES. UNDERSTANDA RULES-BA EMERGING MARK TRANSPARENT SIMPLE
STOXX Limited STOXX EMERGING MARKETS INDICES. EMERGING MARK RULES-BA TRANSPARENT UNDERSTANDA SIMPLE MARKET CLASSIF INTRODUCTION. Many investors are seeking to embrace emerging market investments, because
More informationAPA & MAP COUNTRY GUIDE 2018 UKRAINE. New paths ahead for international tax controversy
APA & MAP COUNTRY GUIDE 2018 UKRAINE New paths ahead for international tax controversy UKRAINE APA PROGRAM KEY FEATURES Competent authority Relevant provisions Types of APAs available Acceptance criteria
More informationBelgium Country Profile
Belgium Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Belgium EU Member State Double Tax Treaties Yes With: Albania Algeria Argentina
More informationGlobal Forum on Transparency and Exchange of Information for Tax Purposes. Statement of Outcomes
Global Forum on Transparency and Exchange of Information for Tax Purposes Statement of Outcomes 1. On 25-26 October 2011, over 250 delegates from 84 jurisdictions and 9 international organisations and
More informationJapan signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
30 June 2017 Global Tax Alert Japan signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationGlobal Business Barometer April 2008
Global Business Barometer April 2008 The Global Business Barometer is a quarterly business-confidence index, conducted for The Economist by the Economist Intelligence Unit What are your expectations of
More informationGlobal Tax Reset Transfer Pricing Documentation Summary. February 2018
Global Tax Reset Transfer Pricing Summary February 2018 Global Tax Reset Transfer Pricing Summary Overview The Global Tax Reset Transfer Pricing Summary ( Guide ) compiles essential country-by-country
More informationQ&A. 1. Q: Why did the company feel the need to move to Ireland?
Q&A 1. Q: Why did the company feel the need to move to Ireland? A: As we continue to grow the international portion of our business, we believe that moving to a member state of the European Union (EU)
More informationFOREWORD. Hong Kong. Services provided by member firms include:
2016/17 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
More informationMEXICO - INTERNATIONAL TAX UPDATE -
TTN Conference May 2017 MEXICO - INTERNATIONAL TAX UPDATE - Arturo G. Brook Main Taxes Income Tax Value Added Tax Others Agenda DTTs and TIEAs FATCA (IGA) and CRS Choice of Vehicles Income Tax - General
More informationSwitzerland implements spontaneous exchange of information
29 April 2016 Global Tax Alert Switzerland implements spontaneous exchange of information EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web
More informationUPDATE. COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS. What is CRS? Participating Jurisdictions
www.kensington-trust.com UPDATE COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015
More informationSlovakia Country Profile
Slovakia Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Slovakia EU Member State Double Tax Treaties Yes With: Australia Austria Belarus
More informationTotal Imports by Volume (Gallons per Country)
7/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 05/2017 05/2018 % Change 2017 2018 % Change MEXICO 71,166,360 74,896,922 5.2 % 302,626,505 328,397,135 8.5 % NETHERLANDS 12,039,171 13,341,929
More informationDutch tax treaty overview Q3, 2012
Dutch tax treaty overview Q3, 2012 Hendrik van Duijn DTS Duijn's Tax Solutions Zuidplein 36 (WTC Tower H) 1077 XV Amsterdam The Netherlands T +31 888 387 669 T +31 888 DTS NOW F +31 88 8 387 601 duijn@duijntax.com
More informationTotal Imports by Volume (Gallons per Country)
10/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 08/2017 08/2018 % Change 2017 2018 % Change MEXICO 67,180,788 71,483,563 6.4 % 503,129,061 544,043,847 8.1 % NETHERLANDS 12,954,789 12,582,508
More informationTotal Imports by Volume (Gallons per Country)
11/2/2018 Imports by Volume (Gallons per Country) YTD YTD Country 09/2017 09/2018 % Change 2017 2018 % Change MEXICO 49,299,573 57,635,840 16.9 % 552,428,635 601,679,687 8.9 % NETHERLANDS 11,656,759 13,024,144
More informationTotal Imports by Volume (Gallons per Country)
12/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 10/2017 10/2018 % Change 2017 2018 % Change MEXICO 56,462,606 60,951,402 8.0 % 608,891,240 662,631,088 8.8 % NETHERLANDS 11,381,432 10,220,226
More informationTHE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS
JERSEY BRIEFING November 2015 THE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS At present 93 countries will implement CRS over a two year period commencing 1 January 2016. The CRS initiative
More informationTotal Imports by Volume (Gallons per Country)
2/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 11/2017 11/2018 % Change 2017 2018 % Change MEXICO 48,959,909 54,285,392 10.9 % 657,851,150 716,916,480 9.0 % NETHERLANDS 11,903,919 10,024,814
More informationTotal Imports by Volume (Gallons per Country)
3/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 12/2017 12/2018 % Change 2017 2018 % Change MEXICO 54,169,734 56,505,154 4.3 % 712,020,884 773,421,634 8.6 % NETHERLANDS 11,037,475 8,403,018
More information