GAAR to tax treaty
transactions, it has made no similar statements that
Effective generally as of January 1, China and Hong Kong have entered into a favorable income tax treaty
that should allow increased tax efficiency on funds coming out of China into Hong Kong.
The designation was confirmed after consideration whether a candidate territory or a country retains a special taxation system which is considered harmful under international standards and whether a candidate territory or a country has a tax treaty
with Korea that may be abused for the purpose of tax avoidance.
Riverwoods, IL) has begun the production of International Tax Treaty
Expert Library, an online information service for tax practitioners and legal professionals engaged in research of international transactions.
income tax at the rate of 30%, unless a reduced rate or exemption under a tax treaty
The Government today has released for public consultation Exposure Draft legislation and an accompanying draft Explanatory Memorandum for the implementation of the Multilateral Convention to Implement Tax Treaty
Related Measures to Prevent Base Erosion and Profit Shifting (the Convention).
The revised double tax treaty
"provides for based taxation of capital gains on transfer of shares, instead of residence based taxation," it continued.
India will have to renegotiate the tax treaty
with Singapore to extend the capital gains tax provisions of the recently-concluded tax pact with Mauritius, Finance Minister Arun Jaitley said.
The purpose of the LOB provision is to prevent treaty shopping, defined by the Treasury as the "use, by residents of third states, of legal entities established in a [contracting [s]tate with a principal purpose to obtain the benefits of a tax treaty
between the United States and the other [c]ontracting [s]tate.
Since most of the money in Mauritian accounts has not gone directly from India but has been routed through other tax havens, investigators are facing difficulties as India does not have a tax treaty
with these jurisdictions for getting information on tax evasion.
transfer tax in the absence of a relevant gift or estate tax treaty