How To Read Double Taxation Agreements



Example of benefit from the double taxation convention: Suppose interest on NRAs [clarification required] bank deposits draw 30 percent tax deduction at source in India. Since India has signed agreements with several countries to avoid double taxation, the tax can only be deducted at 10-15% instead of 30%. At the end of the day, it is a political process. Both countries have a double taxation convention, but sometimes it is not easy to share the cake. The development of international trade and multinationals has increased the need to address the issue of double taxation. As a company or individual looking for business opportunities and investments beyond your own country, you would of course deal with the problem of taxation, especially if you will have to pay twice taxes on the same income in the host country and in your country of origin. As a result, you are trying to structure your operations to optimize your tax position and reduce costs that, in turn, would increase your global competitiveness. It is the relevance of the DBA or Singapore`s tax treaties that comes into play. The UN model gives more weight to the source principle than to the principle of residence in the OECD model. In conjunction with the principle of withholding tax, the article of the model agreement assumes that the country of origin recognizes that: (a) the taxation of foreign capital income would take into account the expenses attributable to income from income, so that these incomes are taxed net; (b) taxation would not be high enough to prevent investment and (c) would take into account the adequacy of equity participation. In addition, the UN Model Convention contains the idea that it would be appropriate for the country of residence to extend a double taxation exemption measure through tax credits or foreign tax exemptions, as in the OECD model convention. NOTE: The exemption/reduction in Iceland under the current agreements can only be achieved if the Director of Internal Revenue requests an exemption/reduction on Form 5.42. Until there is an exemption allowed with the number one registered, you have to pay taxes in Iceland.

For a country with very low taxes, the United Arab Emirates has a vast network of double taxation conventions. With agreements in 90 countries – and 33 in progress – the UAE has more double taxation conventions than countries such as Ireland, Luxembourg and Singapore. Given the increase in taxation and the increase in the transfer of information between legal systems, it has never been more important to ensure that consumers receive all the tax breaks and tax exemptions they can obtain under the relevant double taxation agreements. Double taxation can also take place within a single country. This usually occurs when sub-national jurisdictions have tax powers and jurisdictions have competing rights. In the United States, a person can legally have only one residence. However, if a person dies in different states, anyone can say that the person was a resident in that state. Intangible personal property can then be imposed by any state asserting a right. In the absence of specific laws prohibiting multiple taxation and as long as total taxes do not exceed 100% of the value of personal material assets, the courts will allow multiple taxation. [Citation required] To implement the BEPS measures, the United Arab Emirates has signed a multilateral instrument that facilitates the modification of its existing treaties.


  • このエントリーをはてなブックマークに追加


 スマートフォンの方はコチラをクリック 友だち追加