Offshore News: June 2010

3.06.2010: The new piece of anti-tax haven legislation has been introduced into the US House of Representatives. Key points of the International Tax Competitiveness Act include tightening corporate residency rules; making it more difficult for corporations to receive income from IP assets in foreign (low-tax) jurisdictions; repealing the 80% 'active-income' provision; repealing the 'boot-within-gain' rule which allows favourable tax treatment of dividends paid during corporate reorganizations.
Previous clauses like the one mentioned above have met resistance from major business organizations and from Republicans.

25.06.2010: On June 21-22, Hong Kong has signed agreements for the avoidance of double taxation (DTAs) with the UK and Ireland. The agreements were signed by HK's Secretary for Financial Services and the Treasury, together with the UK's Exchequer Secretary to the Treasury.
The DTAs follow the OECD Model Double Taxation Convention, and set out the allocation of taxing rights between the jurisdictions.
HK residents currently receiving dividends from the UK and Ireland are subject to withholding tax, which is 20% in both jurisdictions. Under the agreement, withholding tax rate will be reduced to 15% in the UK and exempted in Ireland. Also, Hong Kong residents receiving royalties and interest from the UK are subject to a current withholding tax rate of 20% in the UK and Ireland. Under both agreements, the withholding tax rate on royalties will be fixed at 3%. The withholding tax on interest will be reduced to 10% in Ireland, whereas it will be exempted in the UK, with a provision to ensure the benefits of the interest article can only flow to residents of the other state.