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Tax Treaty Between
Namibia
and
Romania
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Download:
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Not Available
(opens in new window) |
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File Type:
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Status:
In Force
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Number of
Namibia
Treaties:
5
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See All
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Number of
Romania
Treaties:
56
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See All
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Introductory note on Tax Treaty Planning
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Tax Treaties (double taxation agreements or DTAs) are international agreements or
conventions concluded with the object of eliminating double taxation by the contracting
states. To succeed in international tax planning, it is essential to engage in deep
and far-reaching calculations. Tax treaties themselves and the OECD Commentary on
the Model Convention give you practical hands-on guidance on international tax planning
issues.
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Treaty Shopping under the
Namibia
–
Romania
Tax Treaty
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Treaty shopping is the use of a tax treaty by a person resident in a country that
is not a party to the treaty, i.e. in the present instance by someone who is a resident
of neither
Namibia
nor
Romania. However, it is becoming
more and more difficult to use provisions, which were intended to prevent double
taxation, in such a way that they result, for the purposes of an international tax
plan.
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Tax Treaty news from the OECD
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The OECD has released two reports submitted to its Committee on Fiscal Affairs by
an Informal Consultative Group of business and government representatives. The Reports
address, respectively:
(a) Technical issues relating to granting treaty benefits with respect to income
of collective investment vehicles; and
(b) Procedural barriers to claims for treaty benefits that affect portfolio investors
more generally.
These are issues which may impact on international tax planning transactions.
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Know your Offshore Terms:
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| | Transfer pricing provisions give the tax authorities the power to reallocate profits and losses where the parties are related and/or the transactions in question are not at arm’s length or for a legitimate business purpose. Transfer pricing measures may prevent the coming into operation of an international tax planning that fails to take them into account. | | | | | The entire amount of capital expenditure incurred on scientific research may, subject to certain conditions, be written off under research and development (R& D) incentives, which may have significant tax planning effects, particularly when coupled with patents and similar incentives. Research and development activities may form part of an international tax plan and may contribute toward closing the gap between high tax jurisdictions and tax havens or international offshore financial centers (IOFCs). | | | | | Before an insurance payment can be classified as a premium, two essential factors must be present: risk shifting and risk distribution. To shift the risk, the insured must transfer it to another who has the financial capacity to make good the losses. | | | | | Umbrella offshore funds offer investors the possibility of investing in different portfolios in an offshore vehicle set up in a tax haven or international offshore financial center (IOFC). These may offer a variety of investment strategies incorporated in a single investment vehicle. | | |
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