Double Tax Treaty News

Within the mutual agreement procedure provided for under Article 25(3) of the Luxembourg-Russia Double Tax Treaty, the tax authorities of both countries agreed on a uniform interpretation of Article 10 (2) of the treaty, which pertains to dividends.

The treaty provides for a standard withholding tax rate of 15% which can be reduced to 5%. Luxembourg and Russia clarified that the reduced 5% rate applies provided that the two following conditions are met simultaneously:

(i) an […]

By |February 23rd, 2018|

Cayman Islands not included on EU Blacklist of Non-Cooperative Jurisdictions in Taxation Matters

In December a ‘blacklist’ of 17 non-cooperative jurisdictions in taxation matters was approved and published by the Council of the European Union and the Cayman Islands has not, as expected, been included on such list.

This list has taken over a year to be compiled and uses criteria which focus on:-

tax transparency;
fair taxation; and
anti-BEPS (tax base erosion and profit shifting) measures being implemented.

​Whilst the Cayman Islands is not included on the blacklist, […]

By |February 22nd, 2018|

Additional Tax Reports Required From Russian Divisions Of International Companies

At the end of 2017, a number of amendments to the Tax Code (Federal Law 340-FZ of November 27 2017) came into force which significantly increased the scope of information and documents that Russian divisions of some international companies must submit to the tax authorities. Through the amendments, Paragraph 13 of the Base Erosion and Profit Shifting Action Plan concerning the provision of country-b y-country reporting was implemented into national tax legislation.
The new rules […]

By |February 19th, 2018|