Davčni sporazumi
SPORAZUMI O IZOGIBANJU DVOJNEGA OBDAVČEVANJA

Mednarodno poslovanje in povezovanje nas privede
do bolj podrobne analize davčnih zakonodaj posameznih držav
in podpisanih medsebojnih sporazumov o izogibanju dvojnega
obdavčevanja.

Naši strokovnjaki vam bodo s pomočjo sporazumov lahko učinkovito
pomagali do izbora prave jurisdikcije poslovanja.
 
Aruba PDF Print E-mail
While it was part of the Netherlands Antilles, Aruba at one time had treaties with a number of prominent countries, including the US and the UK.
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Bahamas PDF Print E-mail

Bahamas Double Tax Treaties

Since the Bahamas do not levy direct taxes, there are no double tax treaties between the Bahamas and other countries.

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Barbados PDF Print E-mail

Barbados Double-Tax Treaties

Barbados has a small number of double tax treaties, but the US and Canadian treaties in particular are extremely favourable for certain types of investor.

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Belize PDF Print E-mail
Belize has double tax treaties with the United Kingdom, Sweden, Denmark and the countries of the Caribbean Community (CARICOM)
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Botswana PDF Print E-mail
Botswana Double Tax Treaties

Botswana has double taxation agreements with Russia, India, Namibia, South Africa, the United Kingdom, Sweden, Mauritius and the Seychelles.

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BVI PDF Print E-mail
The British Virgin Islands have double tax treaties with the UK, Japan and Switzerland; in the last two cases, this means just that the UK's treaty with the countries concerned has been extended to the BVI.
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Brunei PDF Print E-mail

Brunei Double Taxation Agreements

Double taxation agreements exist with the United Kingdom (1950), Indonesia (2000), China (2004) and Singapore (2005). Tax credits are only available for resident companies.

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Cayman Islands PDF Print E-mail
Not having any taxes other than customs duties and stamp duty, the Cayman Islands has not entered into any Double Tax treaties with other countries. Cayman has however entered into a mutual legal assistance treaty with the USA; the treaty specifically excludes fiscal matters.
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Cook Islands PDF Print E-mail
The Cook Islands have not entered into any Double Tax or Mutual Assistance treaties with other countries. The Islands have passed other laws dealing with provision of information in respect of criminal matters, but the authorities habitually do not respond to requests for information regarding fiscal matters or tax evasion.
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Costa Rica PDF Print E-mail

Costa Rica Double Tax Treaties

Costa Rica is not a party to any double taxation treaties. However it has signed an exchange of information treaty with the United States with a view to promoting the necessary interchange of tax information and to ensure that the correct level of taxation is levied in both countries as well as to eradicate tax evasion.

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Cyprus PDF Print E-mail

Cyprus Double Tax Treaties

Cyprus has entered into 33 double-tax treaties (unusually for a low-tax jurisdiction). The general effect of these treaties is that Cyprus-registered offshore entities that have tax exemptions in Cyprus will have the same exemptions in the treaty countries (see Tax-Sparing Provisions below).

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Dubai PDF Print E-mail
Dubai Double-Tax Treaties

Dubai is a 'no tax' emirate. Accordingly double taxation treaties are aimed at making Dubai a more attractive territory in which to operate by reducing taxation levied in the foreign jurisdiction on profits remitted abroad by foreign corporations operating in Dubai.

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Grenada PDF Print E-mail
Grenada Double Tax Treaties

Grenada has a double tax avoidance agreement with the UK dating from 1949, with an amending protocol dated 1968.

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Irland PDF Print E-mail

Ireland Double Tax Treaties

Ireland has comprehensive double taxation agreements in force with 44 countries. The agreements generally cover income tax, corporation tax and capital gains tax (direct taxes).

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Jersey PDF Print E-mail
As a matter of policy Jersey does not normally enter tax treaties. However, double taxation agreements exist with the United Kingdom and Guernsey, and a limited agreement with France exempting a resident of either country from tax in the other country on profits from shipping and air transport.
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Labuan PDF Print E-mail
Labuan Double Tax Treaties

In pursuit of foreign investment, Malaysia has signed 62 double tax treaties, of which 50 are in force, mostly having low rates of withholding tax on outgoing payments. Details are given below for 34 of these treaties. A further 13 treaties are under negotiation.

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Latvia PDF Print E-mail

Latvia Double Tax Treaties

Latvia has double tax treaties with 30 countries.

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Liberia PDF Print E-mail

Liberia Double Tax Treaties

Liberia has income tax treaties (double taxation agreements) with Germany and Sweden. A treaty with Canada has been signed but is not in effect while a treaty to avoid double taxation on shipping and aircraft income is in force with New Zealand. In 1982 Liberia and the United States also signed a treaty exempting shipping and aircraft earnings from double taxation. This exemption applies to the operation of ships and aircraft registered in the signatory countries.

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Liechtenstein PDF Print E-mail

Liechtenstein The Austria Double Tax Treaty

The Liechtenstein Double Tax Treaty with Austria has been effective since 1970. The Treaty applies to resident individuals, companies transacting commercial business (ie not investment business), and holding companies, providing these can prove that at least 51% of their capital is held by Liechtenstein citizens.

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Luxembourg PDF Print E-mail

Luxembourg Treaty Provisions

Luxembourg has signed Double Tax Treaties with 39 other countries, all of which follow the OECD Model Tax Convention, although the treaty with the US contains 'Savings' and 'Limitation of Benefits' clauses which can negate the purpose of the treaty in some circumstances.

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Madeira PDF Print E-mail

Madeira Double Tax Treaties

As part of Portugal, Madeira has access to the substantial number of tax treaties entered into by the mother country. Generally speaking, the treaty benefits are available to all Madeiran companies. However, Madeiran companies in the International Business Centre licensed under the Free Trade Zone Legislation are able to remit interest, dividends and royalties to non-residents without the imposition of withholding tax, so that treaty benefits in that instance are not needed.

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Malta PDF Print E-mail
Malta Double Tax Treaties

Malta has entered into 46 double-tax treaties (unusually for a low-tax jurisdiction), with another 15 pending. Generally speaking, the treaty benefits are available to all Maltese companies other than Offshore Companies (being phased out, in any case). All the treaties other than the Swiss and USA treaties, which are limited to air transport and shipping, follow the OECD Model Convention.

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Marshall Islands PDF Print E-mail

Marshall Islands Double Tax Treaties

The Government has not signed double taxation treaties with any countries. However, under the Compact of Free Association with the United States, United States citizens may be relieved of their liability to pay tax in the United States on income earned in the Republic of the Marshall Islands. To be eligible they must have resided in the Marshall Islands for at least 183 days of the taxation year.

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Maurtitius PDF Print E-mail

Mauritius Double Tax Treaties

Mauritius has entered into a considerable number of double-tax treaties (unusually for a low-tax jurisdiction). Generally speaking, the treaty benefits are available to all Mauritian companies other than International Companies.

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Monaco PDF Print E-mail

 Monaco Double Tax Treaties

Monaco has a taxation treaty only with France, and even this treaty, which forms part of the 1963 portmanteau agreement between France and Monaco, is not a double taxation treaty in the traditional sense. It provides for income tax to be levied against French nationals who have or will transfer their residence to Monaco , the imposition of business profits taxes on certain categories of companies and the exchange of information.

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The Netherlands Antilles PDF Print E-mail
The Netherlands Antilles have tended to move away from double tax treaty arrangements during recent years. At one time the country had treaties with a number of prominent countries, including the US and the UK. Most of these treaties have lapsed, and the only remaining double tax treaty as such is with Norway. There is also the 'BRK' tax agreement with the Netherlands. After negotiations to continue the US treaty failed in 1987, the remaining 'mini-'Treaty' continues to give exemption from US withholding taxes to Eurobonds issued before 1984.
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Nevis PDF Print E-mail

St. Kitts and Nevis Double Tax Treaties

The Federation of St Kitts and Nevis is party to double taxation treaties with Denmark, Norway, Sweden, Switzerland, the United Kingdom and the United States of America (limited to social security benefits).

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Russia PDF Print E-mail
The new profits tax law which came into force in 2002 significantly changed the withholding tax regime applying to Russian source income paid to foreign companies without a permanent establishment in Russia. The new withholding tax regime is now much closer to OECD principles and the previously extremely bureaucratic procedure for obtaining advance treaty clearances has been much simplified.
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Seychelles PDF Print E-mail

Seychelles Double Tax Treaties

The Seychelles has Double Tax Agreements in force with China, South Africa, Indonesia, Thailand, Oman, Malaysia, Namibia and Zimbabwe. Negotiations are said to have been concluded with Russia, Botswana, Vietnam, Malaysia, and Egypt.

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Slovenia PDF Print E-mail
1. SEZNAM VELJAVNIH KONVENCIJ O IZOGIBANJU DVOJNEGA OBDAVČEVANJA DOHODKA IN PREMOŽENJA (na dan 1. 1. 2006)
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St. Vincent PDF Print E-mail

St. Vincent and the Grenadines Double Tax Treaties

St. Vincent and The Grenadines (SVG) does not participate in a network of Double Taxation Treaties and thus has no obligation to exchange tax information with any other government. SVG tax authorities habitually do not cooperate with other countries’ tax authorities.

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Switzerland PDF Print E-mail

Switzerland Double-Tax Treaties

Switzerland has Double Taxation Treaties with more than 50 other countries. The general effect of the treaties for non-residents from treaty countries is that they can obtain a partial or total refund of tax withheld by the Swiss paying agent. Although the full amount of withholding tax is deducted at source the difference can be re-claimed by the non resident from the Swiss tax authorities. Where there is no double taxation treaty in place withholding taxes deducted in the foreign jurisdiction on remittances paid to a Swiss entity give rise to a tax credit in Switzerland.

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USA PDF Print E-mail
For the 54 countries set out in the table below, the full text of the treaties is available on the Internal Revenue Service web-site together with technical explanations in most cases. New or changed treaties are currently being negotiated with the United Kingdom, India and Italy.
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