Tax treaty briefing for February 2015

Treaty mutual agreement procedures between contracting parties are likely to become even more necessary as a result of BEPS, with action 14 aimed at speeding the settlement process. Hong Kong’s rapidly expanding treaty network makes it an attractive location as an Asia Pacific hub. Modern technology creates the challenge of analysing whether payments should be subjected to royalty withholding tax. Services rendered abroad are increasingly exposed to foreign tax, especially in jurisdictions such as India. Equipment leasing is a difficult area that can expose rents to foreign tax as a royalty or as business profits