News

An arrangement comprising of an exchange of letters amending the 2008 Tax Information Exchange Agreement (TIEA) with the British Virgin Islands was signed on 28 November 2013 to permit automatic and spontaneous exchange of information. At the same time an agreement was also signed to improve international tax compliance which sets out the precise details of the information which will be automatically exchanged.

The intergovernmental agreement between Great Britain and Gibraltar on the automatic disclosure of tax information was signed on the 21 November 2013.

The key feature of this agreement is its non-reciprocity which means UK financial institutions will not have further reporting obligations under the terms of this agreement.

The text of the new agreement is available on the HM Revenue & Customs website.

On 12 November 2013 Law from 24.10.2013 г. № 657-VІІ “On Changes to the Tax Code of Ukraine in respect of recording and registering taxpayers and improving certain provisions” that changed the definition of a "low tax jurisdiction" for transfer pricing purposes (identifying controlled transactions), has been published in the official gazette «Golos Ukrainy», the issue № 212. The list of the low tax jurisdictions will be set by the Cabinet of Ministers of Ukraine.

On 25 November 2013 the European Commission proposed amendments to key EU corporate tax legislation, in particular, the Parent-Subsidiary Directive, in order to significantly reduce tax avoidance in Europe. 

Canada (on 21 November, 2013) and New Zealand (on 22 November, 2013) have ratified the multilateral Convention on Mutual Administrative Assistance in Tax Matters. The Convention will enter into force for both countries from March 1, 2014.

On 7 November 2013 Belgium's Chamber of Representatives, the lower house of the Federal Parliament, endorsed the Avoidance of Double Taxation Agreement ("DTA") signed with China on 7 October 2009.

The Global Forum on Transparency and Exchange of Information for Tax Purposes met on the sixth time in Jakarta, Indonesia, on 21-22 November 2013. During the Jakarta meeting, six new countries became members: Azerbaijan, Dominican Republic, Lesotho, Romania, Senegal and Ukraine.

Double Tax Agreement with United Kingdom has been ratified by the National Assembly and formally published in the official gazette (Gaceta Oficial) on 30 October 2013.

This first-time comprehensive Double Taxation Agreement between the UK and Panama was signed on 29 July 2013.

Important features include exemption from withholding tax on certain dividends and low withholding rates on interest and royalties (not more than 5% if certain conditions are met). The Convention also includes the latest OECD exchange of information article.

The text of the new Convention is available on the HM Revenue & Customs website.

The Convention will enter into force once UK has completed legislative approval processes.

Several Tax Information Exchange Agreements (TIEAs) signed by the Republic of Panama have been ratified by the National Assembly and formally published in the official gazette (Gaceta Oficial):

• on 8 October 2013 – TIEAs with Iceland, Greenland, Finland, Faroe Islands
• on 17 October 2013 – TIEAs with Denmark, Norway and Sweden
• on 30 October 2013 – TIEA with Canada.

On 11 October 2013 the Czech Republic ratified the Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol.

The amendments will enter into force within the territory of the Czech Republic on 01 February 2014.