13.07.2015 Views

1MKgVNE

1MKgVNE

1MKgVNE

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

OmanOman – Switzerland tax treaty concluded22 May 2015 – On 22 May 2015, officials of Oman andSwitzerland concluded a tax treaty with each other (inSugiez, Switzerland). The most notable treaty provisionsare as follows:• The maximum dividend withholding tax rate ondividend distributions amounts to 5% of the grossamount of the dividend if the beneficial owner is acompany (other than a partnership) which holdsdirectly at least 10% of the capital in the distributingcompany, or 15% in other cases. Certain (governmentlinked) institutions and pensions funds are exemptfrom dividend withholding tax.• The maximum interest withholding tax rate on interestpayments amounts to 5% of the gross amount of theinterest. Certain interest payments are exempt frominterest withholding tax (among which interest onbank loans and interest on intercompany loans).• The maximum royalties withholding tax rate onroyalty payments amounts to 8% of the gross amountof the royalty. The treaty also contains a most favorednation (MFN) clause in respect of the royalty article(i.e. if Oman would conclude a tax treaty or similararrangement with a third state in which it agrees ona lower withholding tax rate for royalties, such lowerwithholding tax rate would apply mutatis mutandis tothe Oman – Switzerland tax treaty).• Capital gains on shares are in principle taxableonly in the state in which the alienator is a resident.However, the taxing right is exclusively allocated tothe source state in case the assets of the companywhich it regards consists, directly or indirectly, formore than 50% of immovable property situated inthat country.Oman – Spain tax treaty approved bySpanish Congress and Spanish Senate30 April 2015 – Further to our news report in the thirdedition of this newsletter, the Spanish congress hasapproved the tax treaty between Oman and Spain on30 April 2015. Thereafter, on 27 May 2015, the SpanishSenate approved the treaty. For an overview of the treatycontents, kindly refer to the third edition of this newsletter.Oman – Portugal tax treaty concluded inLisbon27 April 2015 – Officials of Oman and Portugal concludeda tax treaty between the countries. This was done on27 April 2015 in Lisbon, Portugal. A copy of the treatycontents has not yet been made public. Treaty details willbe reported once available.Georgia approved treaty negotiationswith Oman2 April 2015 – The Government of Georgia authorizedto enter into treaty negotiations with Oman. This wouldbe the first tax treaty between the countries. Details havenot yet been made public and will be reported in thisnewsletter once available.Oman – Lithuania tax treaty negotiationshave commenced3 February 2015 – Following a meeting held inMuscat, Oman on 3 February 2015, it was reported thatnegotiations to come to a tax treaty between Oman andLithuania have commenced. Developments on this topicwill be reported once available.QatarQatar – Peru tax treaty negotiationsupdate28 May 2015 – It has been reported by IBFD that a thirdround of treaty negotiations was scheduled to reach a taxtreaty between Qatar and Peru (in Doha, Qatar on 27 and28 May 2015). Reportedly, the previous round of treatynegotiations took place in Lima, Peru. More informationis not yet public and will be reported once available.Qatar – Kyrgyzstan tax treaty enteredinto force26 May 2015 – Following the ratification procedure by bothcountries, the tax treaty between Qatar and Kyrgyzstanentered into force on 4 May 2015. Consequently, theprovisions of the treaty can be benefitted from as of1 January 2016.7

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!