Seychelles advised to redouble BEPS efforts

Posted in Business and Economy, Double Taxation Agreements, International Organisations, International relations at 8:06 pm by Robert Klien

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting.

Ingela Willfors, a UN tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in particular on revising the territory’s double tax agreements (DTAs) through the BEPS multilateral instrument to implement tax treaty-related measures to prevent BEPS.

Following an earlier 5-day visit, Willfors identified that Seychelles currently lacks the resources and capacity to effectively implement the OECD’s recommendations. She recommended that authorities focus on those measures that must be implemented to meet international best standards – namely the BEPS minimum standards, on preventing treaty abuse, the introduction of country-by-country reporting rules, improving dispute resolution mechanisms, and tackling harmful tax practices.

The Seychelles has for the past 2years received support from Sweden on BEPS, as part of a twinning program.


Seychelles and Slovenia to sign DTA

Posted in Business and Economy, Double Taxation Agreements, International relations, Seychelles government at 1:03 pm by Robert Klien

Seychelles and Slovenia have agreed to push for the conclusion of a double tax agreement (DTA), during a meeting held to discuss improving bilateral relations.

Slovenia’s Ambassador, Selby Pillay, said: “Slovenia and Seychelles are connected by many attributes. As small states, we understand each other’s efforts and we would be pleased to share and exchanges experiences in the fields of environment and nature conservation and tourism.”

Following the meeting, a statement was issued to announce that the 2 jurisdictions are holding negotiations towards a DTA, which would ensure that income from cross-border trade and investment is taxed only once. It would allocate the taxing rights of both Seychelles and Slovenia; potentially reduce withholding taxes on dividends, interest, and royalties income; and would likely include tax information exchange provisions.


Seychelles-Singapore DTA comes into effect

Posted in Double Taxation Agreements, International relations at 2:22 pm by Robert Klien

A double tax agreement (DTA) between the Seychelles and Singapore became effective on January 1, 2016, establishing a beneficial framework to encourage cross-border investment and trade.

The agreement entered into force on December 18, 2015, after being signed in July 2014. The documents provides, on certain conditions, that cross-border dividends income will be exempt from tax at source.

It also caps tax on interest income in the source country at 12%, providing that the recipient is the beneficial owner of the interest income and resident in the other contracting state. In some circumstances interest income will exempt from tax at source. Withholding tax on royalties income at source will be capped at 8% or such income will be exempt.

According to the treaty’s provisions on the creation of a permanent establishment, a building site, a construction, assembly, or installation project; or supervisory activities in connection therewith will be deemed to be a permanent establishment if the project or activities last more than 12 months.


Seychelles and Qingdao promoting mutual trade and investment

Posted in Bilateral Treaties, Business and Economy, Double Taxation Agreements, Financial Services, Foreign investments, International Organisations, International relations, Seychelles infrastructure, Seychelles offshore jurisdiction at 1:16 pm by Robert Klien

Seychelles and Qingdao, a major port city of China’s eastern province of Shandong, have widely discussed trade and investment opportunities between entrepreneurs from both jurisdictions.

A 1-day business forum was held on May 12 in the northern part of the Seychelles main island of Mahé, where about 30 local companies and representatives of some 20 businesses from Qingdao could have business-to-business meetings and discuss the possibilities for cooperation in infrastructure, banking, import and export, shipping, and construction.

According to the Seychelles Investment Board (SIB), it had responded to the Qingdao delegation’s proposal to organise the forum as the group are currently on a tour of the Indian Ocean to establish business contacts and develop partnerships.

SIB’s Chief Executive, Rupert Simeon, told SNA that the Qingdao delegation have already been to Mauritius and are now heading to Sri Lanka.

It should be noted that a Double Taxation Avoidance Agreement (DTA) already exists between Seychelles and China allowing businessmen operating in the two countries to pay tax in one of the jurisdictions and avoid taxation in the other, aiming to encourage trade and investment between the two jurisdictions. Also, Seychelles is a member of both the Southern African Development Community (SADC) and the Common Market for Eastern and Southern Africa (COMESA) trade alliances and was recently welcomed as the 161st member of the World Trade Organisation. So, there should be much interest from Chinese businesses especially in the offshore sector that are using the tax structures in place to invest in the region.


Multilateral Tax Cooperation Treaty signed by Seychelles

Posted in Double Taxation Agreements, International Organisations, International relations, Seychelles government, Seychelles legislation, Seychelles offshore jurisdiction at 7:28 pm by Robert Klien

On February 24, Seychelles became the 85th signatory of the Organisation for Economic Co-operation and Development’s (OECD’s) Multilateral Convention on Mutual Administrative Assistance in Tax Matters.

The Convention is a comprehensive multilateral instrument to tackle tax evasion and increase transparency. According to a statement made by the OECD, the signing therefore represents another important step in Seychelles’ efforts to improve its legal framework and practices as regards the exchange of information for tax purposes.

The Convention provides for all forms of administrative assistance, in tax matters, including the exchange of information on request and automatically; in tax examinations abroad and in plurilateral investigations; and in tax collection.

The OECD added that it has repeatedly called on all jurisdictions to sign the Convention and has asked the Global Forum on Transparency and Exchange of Information for Tax Purposes to report on progress made by its members in that respect.


Seychelles and Guernsey sign DTA

Posted in Double Taxation Agreements, International relations, Seychelles offshore jurisdiction at 9:03 am by Robert Klien

A double taxation agreement (DTA) was signed between Seychelles and Guernsey on January 27, 2014. The document between the territories was signed in London by the High Commissioner for the Seychelles, Marie-Pierre Lloyd, and Guernsey’s Minister for Treasury and Resources, Gavin St Pier.

According to the Government of the Seychelles, the DTA would encourage nationals of both jurisdictions to increase bilateral trade and investment as well as provide for certainty with regards to taxes payable on income generated from investments made between Seychelles and Guernsey.

The double taxation agreement sets out permanent establishment rules that apply to income tax in Guernsey, and business tax, income and non-monetary benefits tax, and petroleum income tax in the Seychelles. Also, this document provides for a zero withholding tax rate for dividends and interest, and for a maximum five percent withholding tax to be imposed on royalties.

The DTA enables the tax authorities of both jurisdictions to exchange taxpayer information, even if a tax authority does not require the information itself, and even if the information is held by a bank or other financial institution.


Seychelles-South Africa DTA Protocol comes into effect

Posted in Double Taxation Agreements, International relations at 3:50 pm by Robert Klien

It has been announced that the protocol to the existing double taxation agreement (DTA) between the Seychelles and South Africa has been ratified and went into effect on May 15, 2012.

This protocol was signed on April 4, 2011 to update the double taxation agreement. It reflects the introduction of the South African dividends tax, which has replaced the secondary tax on companies from April 1, 2012, and is being levied at a rate of 15% on shareholders.

However, for residents of the Seychelles receiving dividends from South African companies that rate will be 5% of the gross amount of the dividends if the beneficial owner is a Seychelles company which holds at least 10% of the capital of the company paying the dividends; or 10% of the gross amount of the dividends in all other cases.

Also, the protocol incorporates the internationally-agreed standard for the exchange of information for tax purposes into the existing DTA.


Seychelles and Sri Lanka sign DTA

Posted in Double Taxation Agreements, International relations, Seychelles government, Seychelles legislation at 2:21 pm by Robert Klien

An agreement aimed at avoiding double taxation and preventing fiscal evasion with respect to taxes on income has been signed between Seychelles and Sri Lanka.

The double tax treaty was signed in Colombo by the commissioner general of Sri Lanka, K.M.S. Kandegedara and Jennifer Morel from the Seychelles Revenue Commission.

It should be reminded that communications on double tax avoidance were initiated in May 2008 by Seychelles authorities and acknowledged in July 2008 by Sri Lanka. The two countries agreed to have the 1st round of negotiation in Seychelles on December 15-19, 2008 whereby agreement was reached on all articles. So, the document was initialed on December 19, 2008.

When ratified by both parties, the signing of this DTA brings Seychelles’ double taxation agreement number to a total of 17.


Seychelles-Kenya DTA initialed

Posted in Business and Economy, Double Taxation Agreements, International relations at 2:55 pm by Robert Klien

On July 21, Seychelles and Kenya initialed the signing of an avoidance of double taxation agreement (DTA). The agreement was initialed by Seychelles’ principal secretary for Finance and Trade Ahmed Afif and Kenya’s deputy director for economic affairs Martin Gumo.

When the DTA is signed, it will be easier and cheaper for the two neighbouring countries to trade.

The DTA will provide certainty with regard to taxes payable on incomes generated from investments made between the 2 jurisdictions. According to Mr Afif, “it also provides an inducement to nationals of both countries to focus their attention on increasing trade, investment and employment opportunities”.

The document is expected to be signed by the end of the year 2011.

Seychelles already has 14 such agreements in force. Also, the jurisdiction is targeting to sign 40 DTAs with different countries.


Seychelles and Bahrain sign DTA

Posted in Bilateral Treaties, Double Taxation Agreements, Seychelles offshore jurisdiction at 11:05 am by Robert Klien

During a recent visit to the USA, the Seychelles’ Minister of Finance, Danny Faure, and Bahrain’s Minister of Finance, Shaikh Ahmed bin Mohammed Al Khalifa, signed an agreement for double taxation avoidance (DTA) between the jurisdictions.

The new agreement is a reciprocal arrangement between the Seychelles and Bahrain not to tax the repatriated income that an individual or corporate resident of one jurisdiction has earned in another one and which has already been taxed.

The new document applies to taxes on income and capital imposed in the Seychelles and Bahrain, irrespective of the way in which they are levied. It includes capital gains taxes on real estate and company shares and taxes on income.

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