sep 182021

Both countries generally apply the imputation method to eliminate double taxation. However, the United Kingdom will exempt dividends paid by a Senegalese company to a company established in the United Kingdom if the conditions for exemption under United Kingdom law are met. The exemption may also apply to the profits of an establishment in Senegal of a British company if the conditions for exemption under British law are met. Prior to the December 2003 agreement, royalties collected by a Hong Kong citizen from a Belgian source not attributable to a permanent establishment in Belgium were subject to a Belgian withholding tax of 15% on the gross amount of royalties, less a fixed deduction of 15%. Under the agreement, the Belgian withholding tax was reduced to 5% of the gross amount of the royalties (excluding a fixed deduction of 15%). In the case of interest received by a Hong Kong resident which is received in Belgium and which is not attributable to a permanent establishment in Belgium, the Belgian withholding tax has been reduced from 15 % of the gross amount to 10 % in accordance with the Agreement. Where a company is established in both Contracting States, the competent authorities shall determine by mutual agreement the domicile of the company for the purposes of the Treaty. In the absence of an agreement, the undertaking is not entitled to the advantages of the Treaty, with the exception of those referred to in Articles 21 (elimination of double taxation), 23 (non-discrimination) and 24 (mutual agreement procedure). The agreement also plays a role in protecting the Treasury by providing for provisions to combat tax evasion and avoidance, including through measures providing for the exchange of information between tax authorities. All recent UK double taxation treaties largely follow the approach taken in the Organisation for Economic Co-operation and Development (OECD) Model Convention on Income and Capital. The agreements provided for the College continue this approach. Under the agreement, Hong Kong residents who receive dividends from New Zealand that are not attributable to a permanent establishment in New Zealand are subject to a reduced withholding tax of 15%. The withholding tax rate will be further reduced to 5% or 0% for qualified beneficial owners.

Hong Kong residents who receive royalties from New Zealand pay a withholding tax limited to 5%. In addition, Hong Kong airlines that fly to Brunei are taxed according to the DBA at the Hong Kong corporate tax rate (lower than Brunei). Profits from international shipping made by Hong Kong residents, but which are currently taxable in Brunei, are exempt under the agreement. Learn about tax rates, the latest tax messages and information on double taxation treaties with our specialized online resources, guides and useful links. The table below lists the countries that have concluded a double taxation treaty with the United Kingdom (as of 23 October 2018). An up-to-date list of active and historical double taxation treaties can be found on the UK Government`s website. In November 2010, the Hong Kong-Luxembourg DBA was updated to include the article on information exchange, so that the agreement is in line with the international standards of the Organisation for Economic Co-operation and Development. Agreements between the two tax administrations of two countries should enable administrations to eliminate double taxation. It is much more common to use the services of a qualified and experienced accountant in applying for tax relief through double taxation treaties. . . .

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