In favor of the Greece-Singapore agreement for the avoidance of double taxation ND-SYRIZA-KINAL

With the votes of ND, SYRIZA and the Movement for Change, the plenary session of the Parliament approved the Greece-Singapore agreement for the elimination of double taxation and the avoidance of tax evasion. The KKE and the MERA25 opposed the convention. “Present” stated the Hellenic Solution.

In the previous discussion, Undersecretary of Finance Apostolos Vesyropoulos said that the double taxation agreements concluded by Greece fall within a regulatory framework bearing the stamp of the OECD and the goal is for the two states not to impose a tax on the same taxpayer for the same income. of the same time period. “Today’s agreement serves the long-term goal of creating an attractive and stable tax framework to boost economic activity,” said the Undersecretary of Finance, adding that the agreement fully covers Greece’s interests and that its main points are:

– the concept of permanent establishment is defined and the conditions under which a permanent establishment is established are recorded in detail.

– determines the tax treatment of various categories of income, such as real estate, business profits, shipping and air transport, affiliated companies, dividends, interest, rights, capital gains, employment income, artists and athletes, pensions, students, other income services.

– determines that income derived by a resident of a Contracting State from immovable property situated in the other Contracting State on account of its own leasing or any other use of such property may also be taxed in the State in which the immovable property is situated. In particular, the concept of real estate is defined and it is stipulated that these provisions will also apply to the income from real estate – companies.

– the general principle is that each state has the exclusive right to tax the profits of one of its undertakings unless that undertaking carries on business in the other Contracting State through a permanent establishment.

– with regard to the taxation of profits from the operation of ships in international transport, the criterion of the state of the ship’s registry is established, in accordance with the established Greek position. In the case of taxation of the profits of a company of a Contracting State from the operation of aircraft in international transport, they shall be taxable only in that State.

– the right to reform and further determine the taxable profits of the enterprise of a Contracting State is provided for if it is found that the principle of equal distances has not been observed in the transactions of that enterprise with a related undertaking of the other Contracting State.

– the framework for the taxation of income from dividends paid by a company of one Contracting State to a resident of the other Contracting State is formed. Exclusive taxation is not provided as a general rule, neither in the State of origin nor only in the State of residence of the beneficiary, except that dividends may be taxed in the State of residence of the beneficiary.

the right to tax the rights is retained in the beneficiary’s state of residence. At the same time, however, the source state also recognizes the right to tax, in accordance with its domestic law. However, the tax payable, provided that the beneficial owner is a resident of the other Contracting State, shall not exceed 7.5% of the gross amount of the rights.

– the tax treatment of the benefit resulting from the sale of real estate is determined. The right to tax this income is granted to the state where the real estate is located. At the same time, however, the beneficiary’s country of residence retains the right to tax this income. It also regulates the tax treatment of benefits resulting from the sale of movable property of a single establishment which an enterprise of a Contracting State retains in the other Contracting State, where a tax right is vested in that State retaining the tax right of the first Contracting State. Profits from the sale of ships or aircraft engaged in international transport or movable property belonging to the undertaking associated with the operation of those ships or aircraft shall be taxable only in the Contracting State in which the profits of those ships or aircraft are taxed.

Income from employment of a resident of a Contracting State in respect of services rendered in another State may be taxed in that other State subject to certain conditions. Also, pensions and other similar remuneration paid to a resident of a Contracting State in respect of previous employment in the other Contracting State shall be taxable only in the first State of residence.

– the Convention establishes the exchange of information between the competent authorities of the Contracting States, with a view to the proper determination of the taxable matter, the treatment of tax evasion and the avoidance of taxation.

SYRIZA rapporteur Sultana Eleftheriadou stated that the agreement provides for a fair and stable tax system in order to avoid double taxation and tax evasion and was signed when SYRIZA was in power in the country. At the same time, however, he pointed out that tax evasion is a plague for Greece and for this, as he stressed, the culture of the Greeks is not responsible but the main reason is the lack of political will. The MP said that many financial scandals, during the years of rule of ND and PASOK, went unpunished and many times instead of punishing the perpetrators of scandals, those who reveal them are punished. Ms. Eleftheriadou referred to the call for an apology from journalist Costas Vaxevanis to note that now “Greece is a country where the practice of investigative journalism is dangerous, as the Vice President of the Commission noted a while ago.”

He also said that in Greece, not journalism of opinion is being prosecuted, but investigative journalism and added that the distortion of the Novartis scandal, by the government of ND, has grown and after terrorizing witnesses, he beheaded an active prosecutor, after ignoring his opinion. , is now clearing its accounts, with the journalists who revealed this scandal and with its political opponents. Sultana Eleftheriadou also said that ND must answer “what is happening with its loans, what is happening with the case of the inaccurate whereabouts of Mr. Mitsotakis, what is happening with the Petsa list, what is happening with the shipowners’ loans that were written off, what is happening with the debt of Mr. Piladakis, what is happening with the direct assignments, during the pandemic “.

KKE MP Ioannis Delis said that this agreement, which was prepared and signed by the SYRIZA government, based on a model contract of the OECD toolbox and which today unites ND, SYRIZA and the Movement for Change, is a contract that concerns major Singapore-based corporations and executives, mostly shipowners, are a contract that introduces tax breaks and lower tax rates at the same time as workers’ rights are being violated.

“After all, who is this agreement with distant Singapore? Who is affected by this agreement that unites ND, SYRIZA and KINAL? It concerns the natural and legal persons, the tax residents in Greece who are active or earn income in Singapore. “I do not know many. It concerns large companies and their executives,” said Ioannis Delis, who added that it is a typical case of facilities for shipowners, the Greek shipping capital which, “in addition to the constitutional guarantee of provocative tax exemptions and privileges in Greece, manages to protect these privileges even from transnational conventions, such as today “.

Hellenic Solution expert Vassilis Viliardos, who said his party would vote “present” because of the risk of tax cuts, said many companies were setting up offshore in Singapore, a “tax haven” country that has a low taxation and an opaque banking system “.

Mr. Billiardos commented that “the contract seeks, according to its title, the avoidance of tax evasion, while no list has yet been made of Lagarde, Bourgeois, Panama papers, Paradise papers and now the Pandora papers of Cyprus, nor “The fuel contract” said that this contract serves shipping companies and trade services, due to remittances from shipping. The Hellenic Solution MP also pointed out that in 2019, when the specific agreement was signed, the Singapore Ministry of Foreign Affairs appointed Mr. Theodoros Kyriakou as Honorary Consul General, to support the work of the Singaporean ambassador to Greece.

MEPA25 spokesman Giorgos Logiadis pointed out that the government brought the Greece-Singapore convention with the start of the new year, as if this is the first priority for the persecuted Greek people, at a time when thousands of people are dying from the pandemic and to be precise, at the time that in order to close a department in schools, 50 + 1 must be ill, and the government takes decisions as a private SA.

“The current bill does not apply to all those who work 180 days a year, exclusively to pay taxes to the state. It does not apply to all those whose purchasing power is at the bottom of the eurozone and can not live,” said George Logiadis He added that “the bill does not concern the new generation of debtors in the tax and insurance funds, with low incomes. But it concerns all those who enjoy timeless privileges without repaying the slightest, it concerns the huge shipping companies, the hydrocarbon mining companies.”

Source: AMPE