ITRCE features: To ensure complete access to all features and functions of International Tax Research and Compliance Expert, please use the following:

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1 International Tax Research and Compliance Expert (ITRCE) is a comprehensive integrated online solution that is designed to speed-up international tax planning, research and compliance workflows. ITRCE s user friendly and intuitive architecture comprises of several features that are designed keeping in mind the five must-haves for every international tax practitioner Worldwide Tax Rates & Laws, Treaties & Analyses, Tax related News, Tax Forms for Compliance and Planning Calculators. ITRCE features: View all tax rates for over 120 countries including CTR, Cross Border, VAT and Individual rates and instantly generate tax rate memos reflecting your company s actual projections. Access worldwide tax treaties in English, summaries of the key treaty terms used, best WHT rates for several payment streams, and other related documents including OECD, UN, US and EU models and directives. Find country-specific tax laws, Compliance checklists and dynamic Analysis documents with embedded research and planning tools to perform calculations using your actual tax attributes. Stay up-to-date on the latest developments in regulations from various countries by reading ITE's comprehensive monthly newsletter. It includes sections covering Approved Changes, Proposed Changes, and Treaty Developments. Perform calculations with your inputs using NOL, Transfer Pricing, Thin Capitalization, Cross Border Transaction, Interest & Penalty, Withholding Tax Minimizer planning calculators. Find foreign tax forms translated into English with the ability to translate and compare your own documents including your actual filed tax return forms, audit notes, financial statements, etc. To ensure complete access to all features and functions of International Tax Research and Compliance Expert, please use the following: Web Browsers Chrome, IE9 or higher, or Firefox Latest version of Adobe Reader 2014 Thomson Reuters/Tax & Accounting. All Rights Reserved.

2 1. You can access ITRCE from the left pane of the Tools tab - by selecting International Tax Tools. Note: You can also access ITRCE from the Search Pane in the International Practice Area. 2. Select Int l Tax Research Expert. Then click Continue to launch ITRCE in a new window. 2

3 3. The International Tax Research and Compliance Expert Home page opens in a new window. ITRCE s Library provides various tools and features for all your research, planning and compliance needs: Research Find key country-specific tax facts, worldwide tax treaties, tax law changes and updated rates tables for all countries supported by ITRCE. Planning Perform calculations reflecting your company s actual attributes using the following calculators: Cross Border Transaction Calculator find total tax cost of your cross border payments. Withholding Tax Minimizer find best routes to structure your cross border transactions in order to reduce your WHT dues. Net Operating Loss Carry Forward Calculator determine how to best utilize your available NOLs. Thin Capitalization Calculator determine how the how the local country s thin capitalization rules impact the total tax cost of making interest payments from the local entity to your company. Transfer Pricing Calculator find how transfer pricing ratios are calculated for the required TP method in the local country and determine the variance between actual and targeted ratios. Compliance - Meet compliance obligations, both local and international, using the following features: Compliance Checklists - find key tax compliance facts including filing requirements, interest and penalties on late and incorrect returns, statutes of limitations, refunds, etc. applicable in the local country. Anti-Avoidance Checklists - find local country rules for Anti-avoidance, Limitation of Benefit clauses, Transfer Pricing, CFC (controlled foreign corporation) and Thin Capitalization. Interest & Penalty Calculator perform calculations for the infractions supported by ITRCE and generate Tax Memos for the same. Forms find key tax forms for all countries, including corporate tax return forms, treaty benefit claim forms, withholding tax reporting forms, registration forms, etc. 4. You can access these features in one of three ways: (1) from the menu bar across the top, (2) from the list of features on the right side of the Home page, (3) and from the drop-down menu What would you like to do today? 3

4 Find current CTR Rates table for multiple countries 1. Select Corporate from the Rates dropdown from the menu bar across the top. 2. From the resulting Corporate screen, choose Search Current Rates By Multiple Countries option and click on Select All. 4

5 3. Click Search. CTR current Rates table for all country(s) is displayed on the screen. Note: Besides an updated database of current CTR Rates, Orbitax also lets you research historical and/or future rates. To perform historical searches, select Search Historical or Future Rates option from the Corporate screen. 5

6 Overview of the CTR Rates table Once ITRCE returns the results for your specified search criteria, use the CTR Rates table to access several other features to aid your research. 1. Click and icons corresponding to the required country within the table to view any applicable Footnotes and Progressive Rates. 2. Click icon corresponding to the required country under Tax Return Due Date column to view Important Compliance dates. 6

7 3. Click icon corresponding to the required country under Entity column. This will redirect you to News tab where you can view the recent tax law changes for that country. 4. Click Printer-Friendly Version to download the search results as a Pdf or Doc file. You can then print/share your search results. 5. Click Export to Excel to export and download your search results as an.xlsx file. 6. Click icon under Rate Memo column corresponding to the required country to generate a CTR Tax Memo. This will redirect you to the Rate Memo screen where you can generate a CTR Tax Memo reflecting your actual Taxable Income projections in that country. 7. Click icon corresponding to the required country under Corporate Tax Return Form column. This will redirect you to the Forms tab where you can view, translate and compare CTR Return Forms for that country. 7

8 Use the Cross Border feature to find withholding tax rates applicable in the required countries and the total tax costs for your anticipated cross border transactions. 1. Select Cross Border from the Rates dropdown menu to display Cross Border screen. To choose only one paying country, select the country from Choose a Country dropdown under Paying. Then, choose all countries from Choose Countries dropdown under Receiving. Note: For one receiving and all paying countries, click the activated switch icon placed between the paying and receiving fields. This will reverse the payment direction and you will be able to see multiple countries selected under Paying. 2. Choose the Payment Stream, Ownership % and Holding Period in the available fields under Conditions and click Search. 8

9 3. The page refreshes and displays the search results. Click the displayed rates below Withholding Tax %, Taxable Portion % or Matching Credit % columns corresponding to the required payment transaction. This generates a pop-up with Best, Domestic and Treaty Rates for your anticipated transaction. 4. Click icon under Withholding Tax % column to switch to the Withholding Tax Minimizer tool to find the best route for your cross-border payment with reduced WHT tax dues. 5. Click icon under Tax Cost (Benefit) column to switch to the Transaction Calculator tool to calculate the total tax cost of your anticipated crossborder transaction. 6. Click icon corresponding to the required country under Paying or Receiving Entity columns. This will redirect you to News tab where you can view recent tax law changes for that country, if any. 7. Click icon under Tax Treaty column to switch to Treaties tab where you can access the translated Treaty document and related commentaries. 8. Click icon under Rate Memo column corresponding to the required cross-border transaction to generate a WHT Tax Memo. This will redirect you to Rate Memo screen. Note: Use Export to Excel/Printer-friendly Version options to download/print your search results. 9

10 Use the VAT Rates feature to find Value Added Taxes and other local taxes applicable in a country. 1. Select VAT Rates from Rates dropdown menu. Note: To find Individual Rates select Individual Rates from the dropdown instead. 2. View the VAT Rates table for all the countries supported by ITRCE arranged in alphabetical order. Additionally, enter the required country name in Search Country field to locate the country-specific VAT Rates in the table. 3. Click icon corresponding to the required country within VAT Rates table to view any available Footnotes. 4. Navigate to the Export/Print Page options available at the top-right of the screen to export/print/save the VAT Rates table. 10

11 1. Click Recent Changes placed at the top-right of Corporate or Cross Border Rates screen for a quick search on any recent changes in worldwide tax rates, Note: ITRCE s Rates tables are updated every four weeks. 2. This opens the link to Orbitax s date-stamped Tax Rate Changes online database page in a new window. Note: You can print/download the tax rate updates from the open link. To save the updates as an Excel file, click icon at the top-left of the screen and select Download Excel (.xls). 11

12 ITRCE s Advanced Search feature lets you find countries satisfying your company s tax search criteria. 1. Select Advanced Search from Rates dropdown menu to display Advanced Search screen. Here, select a paying country from Choose a country dropdown under Paying. Then, click Select All link from Choose a country dropdown under Receiving. 2. Click Check All under Payment Stream. Then, choose the required values from Holding % and. Holding Period dropdowns. 3. Under Search Criteria on the right, use the Relationship dropdown along with the two value fields placed next to each available search criteria to specify your condition. 12

13 4. Alternatively, choose an entity type that matches your key tax search criteria from Find Entities dropdown at the bottom of the page. Note: Choosing an entity type from Find Entities dropdown will reset values under Payment Stream and Search Criteria sections. 5. Scroll down to the bottom of the page and click. The page refreshes and displays the search results. Click icon under Treaty column to switch to Treaties tab where you can access the translated Treaty document and related commentaries. Click Printer-Friendly Version to download the search results as a PDF or Doc file. You can then print/share your search results. Click Export to Excel (with formulas) to export and download your search results as an.xlsx file along with the formulas used by ITRCE for calculations. Click icon corresponding to the required country under Paying and Receiving Country columns. This will redirect you to News tab where you can view the recent tax law changes for that country, if any. Click icons to read any available Footnotes about the Treaty rates applicable to the corresponding payment transaction. 13

14 Use the Rate Memo screen to generate, print and download desired Tax Rate Memos. From the Rate Memo screen you can generate two types of memos: (a) Corporate Tax Memo and (b) Withholding Tax Memo. 1. Select Rate Memo from the Rates dropdown menu. The Rate Memo screen is displayed. Select the radio button next to Corporate Tax under Memos Types. 2. Select the required country from Choose Country dropdown and enter your actual projections in Taxable Income field. Note: Once you have chosen the country where your entity is located, ITRCE updates the rates fields on the screen with the rates applicable in that country. 14

15 3. If you want to edit the default CTR Rates, enable the checkbox next to Change Default Corporate Tax Rates and make the desired changes in the rates fields. 4. Click View Memo. ITRCE performs calculations using your inputs and displays the generated Corporate Tax Memo on the screen. 5. To save/download/print the generated memo, scroll up and use options at the top of the screen. Note: You can download the memo as a PDF, a Doc or an HTML file. Note: To generate a WHT Memo follow the steps described above choosing WHT Memo type instead. 15

16 ITRCE's Newsletters covers worldwide tax law changes under Approved Changes, Proposed Changes, and Treaty Developments categories. ITRCE s News Library is updated on a daily basis. To search daily news about worldwide tax law changes: 1. Select News from the menu bar across the top and click Daily News at the top of the News screen. The Daily News is displayed on the screen. 1. You can search Newsletters by country, date or both. To search news about tax law changes by country, select the required country from Choose a Country dropdown under Search Newsletters. Note: Use Advanced Search feature to search news about tax law changes in the local country within a given time period. 16

17 2. News found for the country is displayed on the screen with most recent news articles at the top. Choose between Approved Changes, Proposed Changes and Treaty Developments sections to read more. Note: Save/download/print the displayed newsletter using Print Page option at the top of the screen. You can download the newsletter as a PDF, a Doc or an HTML file. 1. To subscribe for the Newsletters, select Subscribe to Our Newsletter from Newsletter screen. 2. Make your selections using Select a country dropdown. Click Select All if you want to receive news about all the countries supported by ITRCE. 3. Enter your address in the field and click Subscribe To Our Newsletter. 17

18 ITRCE s Country Analysis provides you with Dynamic Documents and Checklists wherein you can not only research various options available in the local countries to optimize your international business structure but also perform critical calculations from within the dynamic documents to better evaluate your tax costs and obligations. Using Country Analysis you can carry out the following tasks: Conduct research on local country tax laws and regulations for over 100 countries with emphasis on cross border tax issues such as types of businesses allowed, PEs status, worldwide tax cost of choosing different entity types, NOL utilization, applicable WHT rates, CFC, Thin Capitalization and Transfer Pricing rules in the local country, etc. Access embedded research and planning tools within the dynamic documents to calculate the impact of local country tax rules on your local and worldwide tax dues. Evaluate the impact of implementing tried and tested international tax planning strategies such as maximizing debt and minimizing WHT in the local country to optimize worldwide tax, etc. Generate Tax Memos reflecting your company s actual projections. View and compare Compliance and Anti-avoidance Checklists of all countries supported by ITRCE to meet your tax obligations. 1. Select Analysis from the menu bar across the top to display the Country Analysis. Here, choose a country from Select Country dropdown to view related analysis documents. 18

19 2. Click Done once you have made your selection. The page refreshes with following documents listed out under Documents in the left navigation panel: Country Summary a summary of the key tax laws applicable in the local country along with relevant explanations Country Chapter in-depth coverage of the local country tax laws along with embedded tools in this dynamic document Country Snapshot quick answers to local country tax laws related queries Compliance Checklist information about tax compliance obligations to be met in the local country Anti-Avoidance Checklist anti-avoidance rules applicable in the local country 3. Click a document title under Documents to view the document. The document will be displayed on the right. Note: Download/print an open document from Country Analysis using Download/Print Page options at the top of the screen. 19

20 4. Click on a section s title from the Table of Contents to view that specific section in the document. Note: You can also access the Table of Contents for the open document from the left navigation panel. 5. This displays the required section of the document. Hover over the section heading to view Print & Compare features for that section. 20

21 Country Chapter document under Country Analysis covers in-depth analyses, explanations and implementable tax strategies for local country s tax laws. It also contains various embedded research and planning tools within its dynamic content which can be used to calculate the impact of local country tax laws on your local and worldwide tax dues. Embedded tools included within a Country Chapter document: Create Legal Presence Advanced Rate Search Transaction Calculator Corporate Rate Search Cross Border Rate Search Net Operating Loss Carry-Forward Calculator Withholding Tax Minimizer Interest & Penalty Calculator Transfer Pricing Ratio Calculator Thin Capitalization Calculator Create Legal Presence Use this tool to find a suitable business entity type in order to create a domestic PE in the local country. 1. From Country Chapter, scroll down to section to access the tool. 2. Click icon at the right. In the resulting popup, change values based on your scenario and click Done. 21

22 3. The tool runs the calculation using your inputs and displays the results as below. Decide on an entity type that best suits your scenario using these results. 22

23 Advanced Rate Search To find entities that match your specific tax search criteria, access this embedded tool within the following sections of the Country Chapter document: Withholding Tax Rates Table Find best WHT rate (i.e. lower of domestic, treaty and EU WHT rates) on 9 different cross border payment streams from the local country to multiple receiving countries Maximizing Foreign Tax Credits Note: You can also access the Advanced Rate Search tool in the Rates tab. Click here to know more. Transaction Calculator 1. To calculate the total tax cost of your cross border transactions, scroll down to section in the Country Chapter document. 2. Click icon at the right. Anticipated Transaction popup opens. 23

24 3. In the Anticipated Transaction popup, do the following: The country you are viewing this document for is selected as the Paying Entity by default. To change the Paying Entity use the dropdown below. Royalty Copyright will be selected as the Payment Stream by default. Use the dropdown to choose another Payment Stream. Select the Receiving Entity using the dropdown below. Click Add a Country to add a layer to your transaction. You can calculate up to four consecutive payment transactions using this tool. Enter the cross border transaction amount in the Payment fields. Set a status for the Profitability by choosing between Profitable, Loss, Break-even or Custom options in the dropdown. Setting the status to Custom in the Profitability field will refresh the popup and display more fields to enter your case specific values. Specify Ownership % and Holding Period using the two dropdowns. 4. Click Calculate when finished. 24

25 5. The tool runs the calculation using your inputs and displays the results under three collapsible sections: Result Summary, Calculation Assumptions and Result Details. Note: Click icon to expand a particular section in the results. Note: Alternatively, you can access the Transaction Calculator using the following path - ITRCE>Planning tab>calculator. 25

26 Corporate Rate Search Use this tool to find current/historical/future CTR Rates applicable in the local country and generate Corporate Tax Memos reflecting effective corporate tax rate on your net taxable income. This tool is embedded in the following sections of the Country Chapter document: Corporate Income Tax Calculation of Effective Corporate Income Tax for Resident Enterprises Calculation of Effective Corporate Income Tax for Non-Resident Enterprises Note: Alternatively, you can access the Corporate Rate Search tool using the following path - ITRCE>Rates tab>corporate 1. From Country Chapter, scroll down to section titled Corporate Income Tax to access the tool. 2. Click icon at the right and select the years and rate types using Choose Years and Choose Rate Type dropdowns. 3. Click Search when done. 26

27 4. The tool will run the search and display the results on the screen. Click and icons within CTR Rates table to view any available Footnotes and Progressive Blocks. 5. Scroll down to section titled Calculation of Effective Corporate Income Tax to generate a CTR Memo reflecting the effective rate applicable to your actual taxable income. 6. Click icon at the right to open Corporate Tax Rate Memo popup. Enter your net taxable income in local currency into the Taxable Income field. 27

28 7. Click View Memo. The generated memo with total Tax Due is displayed as below. Note: You can also generate, download and print Tax Memos within Rates tab. 28

29 Cross Border Rate Search Use this tool to find WHT tax rates applicable on 9 different cross border payment streams from the local paying country to the receiving country. 1. From Country Chapter, scroll down to section General Rules. 2. Click icon at the right. In the resulting popup, select the receiving country using the Select receiving country dropdown and specify the Holding % and Holding Period. Click Done to run the search. 3. The results will be displayed below in a table. Click and icons within the WHT Rates table to view any applicable Footnotes and Progressive Blocks. Note: To find WHT tax rates applicable on payments from the local paying country to multiple countries, access Cross Border tool within Rates tab. 29

30 Withholding Tax Minimizer Use this tool to find the best possible route for your cross border payments in order to reduce WHT taxes. WHT Minimizer tool in different sections of Country Chapter document reflects a default Payment Stream that best suits the purpose of the calculations specific to that section. The tool is embedded in the following sections of the Country Chapter document and will help you structure your payments to: Minimize WHT taxes incase of no domestic PE (sec ) Minimize WHT taxes incase of domestic PE (sec ) Minimize WHT for Foreign Tax Credits (sec 9.1.2) Minimize Capital Gains taxes (sec ) Note: Alternatively, you can access the Withholding Tax Minimizer tool using the following path - ITRCE>Planning tab> WHT Minimizer. 1. From Country Chapter, scroll down to section titled Structuring Payments to Minimize WHT dues in case of no domestic PE to access the tool. 2. Click icon at the right. Search Option popup opens. 30

31 Choose your Paying and Receiving countries using the two dropdowns. Click Select All entities from the Intermediary 1 dropdown. You can also select a second Intermediary entity using Intermediary 2 dropdown. Royalty Copyright is selected as the Payment Stream by default. Use the Payment Stream dropdown to select one of the 9 payment streams supported by ITRCE. Use the dropdowns to specify Ownership % and Holding Period. 3. Click Search when done. The tool runs the calculation using your inputs and displays the Optimized Results below your Base Case. Note: In this example, the WHT rate for the Base Case is The Optimized Results displays payment routes via intermediary countries such that it reduces the applicable WHT taxes that you would have paid for the base case. The best route suggested in this example gives you zero WHT taxes. 31

32 Net Operating Loss Carry Forward Calculator Use this tool to determine how to best utilize your losses. The tool performs calculations based on your inputs to illustrate the loss carry back and carry forward rules in the local country. 1. From Country Chapter, scroll down to section 7.1 titled Computations of loss carryback and carryforwards to access the tool. 2. By default, the table displays rules for the country you are viewing Country Analysis documents for. To view NOL Utilization rules for another country, use the Country dropdown under Country and Year. 32

33 3. The table refreshes and displays the rules for the selected country under Limitations. Note: You can overwrite any of the NOL Utilization rules under Limitations by entering your desired values in the text boxes under the Overwrite column. 4. Under Input:Taxable Income (Loss), enter your company specific values in the text boxes below the appropriate year. 33

34 5. The tool runs the calculation using your inputs and displays the results in two tables: Calculation Summary and NOL Utilization Details. 6. To download/print the results access the Net Operating Loss Carryforwards Calculator tool using the following path - ITRCE>Planning tab> Net Operating Loss Carryforwards. 34

35 Thin Capitalization Calculator Use this tool to see how the local country s thin capitalization rules will impact the total tax cost of making interest payments from the local entity to your company. The tool calculates the maximum allowable interest payment using your inputs. 1. From Country Chapter, scroll down to section titled Calculation of Maximum Allowable Debt to access the tool. 2. By default, the table displays rules for the country you are viewing Country Analysis documents for. Enter the appropriate value in the Interest Rate textbox under Basic Information. Note: To perform Thin Capitalization calculations for another country, use the Country dropdown under Basic Information. 35

36 3. The table displays Acceptable Debt to Equity Ratio values for the local country. Enter appropriate values in the text boxes provided in the table to calculate Maximum Allowable Interest Amount. Note: You can overwrite the existing values in the table. The table refreshes and displays the results for Maximum Allowable Interest Amount based on your inputs. 36

37 Based on the Maximum Allowable Interest Amount determined from the calculation above, the tool performs further calculations to show the total tax cost of increasing or decreasing the interest payment from the local entity to your company. 4. Scroll down to section titled Interest Deduction Strategies. 5. Click icon at the right. Anticipated Transaction popup opens. 6. In the popup, enter values based on your scenario and click Calculate. Note: Click Add a Country to add a layer to your transaction. You can calculate up to four consecutive payment transactions using this tool. Note: You can set the Profitability of the entities using the Profitability dropdown. Choose between Profitable, Break Even, Loss or Custom status. 37

38 7. The tool runs the calculation using your inputs and displays the results under three collapsible sections: Result Summary, Calculation Assumptions and Result Details. Note: Click icon to expand a particular section in the results. 8. To download/print the results access the Thin Capitalization Calculator tool using the following path - ITRCE>Planning tab> Thin Capitalization. 38

39 Transfer Pricing Ratio Calculator Use this tool to see how the transfer pricing ratios are calculated for the TP methods in the local country. The tool also shows how a change in the transfer pricing amount will impact the variance between the actual and target ratios. 1. From Country Chapter, scroll down to section titled Calculation of Transfer Pricing Ratios and Variance between Target Ratios and Actual Ratios to access the tool. 2. By default, the table displays rules for the country you are viewing Country Analysis documents for. Use Current Transfer Pricing Method dropdown to select a TP method. 3. Enter the appropriate value in the Target Ratio text box under Ratio Details. 39

40 4. Enter appropriate amounts in the textboxes provided below Accounts in the table. 40

41 5. The table refreshes and displays the Actual Ratio and Comparison Ratio results for selected TP Method based on your inputs. Comparison Ratio shows the variance between the actual and target ratios. 6. Scroll down and click icon on the right to calculate how increasing or decreasing the TP will impact the total tax cost. This opens the Anticipated Transaction popup. Here, enter values based on your scenario and click Calculate. 41

42 7. The tool runs the calculation using your inputs and displays the results under three collapsible sections: Result Summary, Calculation Assumptions and Result Details. Note: Click icon to expand a particular section in the results. 8. To download/print the results access the Transfer Pricing Ratio Calculator tool using the following path - ITRCE>Planning tab> Transfer Pricing. 42

43 Interest & Penalty Calculator Use this tool to calculate interest and penalties applicable in the local country for different infraction types. 1. From Country Chapter, scroll down to section titled Calculation of Interest & Penalties of Various Infractions to access the tool. Note: Alternatively, you can access the Interest & Penalty Calculator tool using the following path - ITRCE>Planning tab> Interest and Penalty 2. Select the required Infraction Types using the Calculation Type Name dropdown and enter appropriate values in Calculation For, Dispute Amount and Date of Dispute fields. 3. Scroll down to Interest Section and enter appropriate values in the textboxes under the Overwrite column. 43

44 4. Additionally, scroll down to enter appropriate values in the fields under Monetary Penalty, Tax Deductibility and Statue of Limitations. 5. The tool runs the calculation using your inputs and displays the results under Interest and Monetary Damages sections. 44

45 1. To access Compliance Checklist for a country, select Analysis from the menu bar. Then, select the required country using Select Country dropdown under Country Analysis. 2. Select Compliance Checklist under Documents from the left navigation panel. The Checklist is displayed. Note: Download/print the displayed Compliance Checklist using Download/Print Page options at the top. 3. Click on a section title in the Table of Contents to locate and display that section of the document. You can also access the Table of Contents from the left navigation panel. 4. Hover over a section heading and click Compare to compare the document section for multiple countries. 45

46 5. Select the countries using Search for country dropdown and click Done. 6. The Comparison screen is displayed. Scroll down to compare the document section for selected countries. 7. Download/print the compared compliance rules using Download/Print Page options at the top. You can download the checklist as a PDF, a Doc or an HTML file. 8. Click Done Comparing at the top of the Comparison screen to go back to the open checklist. 46

47 1. Select Analysis from the menu bar at the top to display Country Analysis screen. Here, select the required country using Select Country dropdown under Country Analysis. 2. Select Anti-Avoidance under Documents. Anti-Avoidance document is displayed. Note: Download/print the Anti-Avoidance Checklist using Download/Print Page options at the top of the screen. You can download the checklist as a PDF, a Doc or an HTML file. 3. Click on a section title in the Table of Contents to locate and display that section of the document. Note: You can also access the Table of Contents from the left navigation panel. 47

48 4. Hover over a section heading and click Compare to compare the document section for multiple countries. 5. Select the required countries using Search for Country dropdown and click Done. 6. The Comparison screen is displayed. Scroll down to view the document section for the selected countries. 7. Click Done Comparing at the top of the Comparison screen to go back to the open checklist. 48

49 When you enter a search on ITRCE for treaties signed between countries, you will have access to the following Treaty Documents: Treaty all major worldwide tax treaties translated into English Treaty Status determine the current status of a treaty entered into by any two countries and find treaties signed by those countries with all other countries Treaty History find the history of amendments and protocols made to the treaty Treaty Analysis read the proprietary document created by Orbitax providing essential explanations and analyses of key treaty terms and conditions stated in a treaty MoUs, Protocols, Notes and Technical (wherever applicable) Withholding Tax Rates and Forms find best WHT rates for all 9 different payment streams along with original and English versions of forms to claim any WHT reductions provided for by a treaty Besides Treaty Documents, ITRCE also provides access to additional guidelines such as Orbitax s commentary How To Read Treaty and Related EU, OECD, UN and US Material (guidelines, models, directives, etc.). 1. Select Treaties from the menu bar across the top to display Worldwide Tax Treaties screen. Here, select the two required countries using the two dropdowns available under Select Countries to view available Treaty Documents for the two selected countries. 2. The list of available Treaty Documents is displayed under Documents in the left navigation panel. Any Active Treaty document translated into English opens by default on the right. Note: Read Orbitax s proprietary commentary How to Read Treaty located within Other Documents to interpret silent issues in a treaty. 49

50 From the Treaty Status screen under Worldwide Tax Treaties, you can ascertain the status of any treaty signed between the two required countries. ITRCE reflects the Treaty Status by assigning appropriate labels to the treaty in question. The four labels used by ITRCE are: 1. Active (i.e. in effect) 2. Signed (i.e. not yet in effect) 3. Terminated (i.e. no more in effect) 4. Unperfected (i.e. not yet completely agreed upon) 1. Select Treaty Status from the list of Treaty Documents displayed under Documents tab for the two selected countries. 2. Treaty Status screen is displayed on the right. Check the current status of the required Treaty under Status. 3. Click icon under Treaty column to display the translated Treaty Document. 4. Click icon next to the required country below the Treaty Status table to expand the table and view the history & status of all other treaties signed by the country with all other countries. 5. Download/print the Treaty Status document using Download/Print Page options at the top of the screen. 50

51 ITRCE s Treaties Library provides you access to its editorial Treaty Analysis document which covers the essentials terms and rules stated within a Treaty document. A Treaty Analysis document contains the following sections: Residence Permanent Establishment issues Royalty issues Capital Gains FTC and Tax Sparing Credits MFN Clauses LOB and Other Exclusions from Treaty Benefits Specific Provisions on use of Domestic Anti-Avoidance Rules 1. Select Treaty Analysis under Treaty Documents in the left navigation panel. 2. Treaty Analysis document is displayed on the right. You can access the Table of Contents for the document in the left navigation panel. 3. Download/print the Treaty Analysis document using Download/Print Page options at the top-right of the screen. You can download the document as a PDF, a Doc or an HTML file. 51

52 From Worldwide Tax Treaties screen, you can find best WHT rates applicable to all 9 types of payment streams from Country 1 to Country Select Country 1 and Country 2 using the dropdowns available under Select Countries and click Done. Country 1 Country 2 2. Select Withholding Tax Rates from the list of available Treaty Documents displayed under Documents. Withholding Tax Rates applicable to payments from Country 1 to Country 2 is displayed on the right. Change Holding Period and Holding % using these dropdowns. Select Withholding Tax Forms to view original and English versions of the forms to claim any WHT rate reductions provided for by a treaty. Note: For WHT Rates applicable to payment transactions from Country 2 to Country 1, reverse the country selections using the dropdowns available under Select Countries. 52 Click and icons within WHT Rates table to view any available Footnotes and Progressive Blocks.

53 Orbitax maintains an updated database of key worldwide tax return forms translated into English. From the Forms screen in ITRCE, you can perform the following tasks: Find worldwide tax return forms translated into English including corporate income tax, value added tax, withholding tax, local tax and registration forms. Translate existing foreign tax forms into any language and compare the translated version side by side with the original language version Translate any PDF document, electronic or scanned, including audit notes, financial statements, local country laws, tax returns, etc. into the desired language Create a certified translation of the tax return form you filed in the local country Quickly perform currency conversions of amounts in your tax related documents 1. Select Forms from the menu bar across the top. After the page refreshes, you will see results for US tax forms displayed on the Forms screen by default. 2. Select the required country using Choose a country dropdown at the top-left of the screen and click Done. 53

54 3. All available forms for the selected country are displayed by default. View a specific tax form by selecting the form type from ALL/CIT/VAT/WHT options at the top-right of forms table. 4. Results for the selected form type are displayed on the screen. Click the title of the required tax form to download it as a PDF. 54

55 1. To translate a form into a different language, click icon under Translate column corresponding to the required form in the Forms table. 2. This opens the Translate Options popup. Choose your preferred language from To Language dropdown and click Translate. 55

56 3. The Translate/Compare Form screen is displayed where you can compare the original language and translated versions of the required form. Use Download/Print options to download/print the original and translated versions of the form. You can choose to download/print both versions side-by-side or each version separately. Click Fix Spacing to remove extra spaces in the translated version of the form. Click Select FX Rates to set the exchange rate for the currency conversions if any in the translated form. Use the central scrollbar provided to compare the two versions of the document side by side. To edit the translated version of the form, simply click on the required spot in the translated document on the right and make the changes. 4. Click at the top-right of the screen to go back to Forms screen. 56

57 You can create a certified English translation of the actual form you filed in the local country and convert currencies using the required FX Rates to reflect the actual amounts in the certified translation. 1. Click icon under Compare column corresponding to the required form from the table in the Forms screen. 2. The Compare Options popup opens. Select the radio button next to Compare your document and upload the already filed tax form using Choose File option. Note: Enable the checkbox next to Treat as scanned if your document is a scanned pdf. 57

58 3. Compare Options popup will refresh. Now, select the language of the actual form using the dropdown available and enable the checkbox next to Create a Certified Translation. 4. Click Compare to view the two documents side by side. Compare/Translate Forms screen opens with the actual form displayed on the left and the certified translation on the right. 58

59 5. To convert currencies in the certified translation, click Select FX Rates. The Convert Currencies popup opens where you can specify settings for the exchange rate you want to use. Specify the local currency using From Currency dropdown. Then, specify the currency you want to convert the amounts to using To Currency dropdown. For the exchange rate you want to use, choose either Spot Rate or Average Rate. The Exchange Rate field refreshes using your inputs and displays the rate for the currency conversion to be used in the certified translation. Enable the checkbox next to Show Notes to include the inputs specified for the exchange rate used. Click Add Note to add another note to the document. Enable the checkbox next to Apply to All to perform conversions for all amounts in the actual form using the specified exchange rate. 6. Click Done to convert the currencies in the certified translation of your document. 7. Use Download/Print Page options to download/print the certified translation of the actual filed form once you have made the necessary edits and finished the required currency conversions. 59

60 Translate and compare your PDF documents, including audit notes, financial statements, local country tax laws, etc. using Translate and Compare features from the Forms screen. 1. Click Translate at the top of the Forms screen. 2. This opens the Translate Document popup. Here, specify the settings for the required translation. Upload your document using Choose File option. Enable the checkbox next to Treat document as scanned if your document is a scanned PDF Enable the checkbox next to Auto Detect Language. Note: This feature will be live soon. Specify the original language of your document using From Language dropdown. Then, specify the preferred language of translation using To Language dropdown. 3. Click Translate to view the original and translated versions in Translate Form screen. 4. From Translate Form screen, click Select FX Rates to convert currency in the translated document. 60

61 5. To compare any two PDF documents, click Compare from the Forms screen. 6. The Compare Options popup opens. Upload both the documents using the Choose File options under Document 1 and Document 2. Note: Enable the checkbox next to Treat as scanned if the uploaded documents are scanned. 7. Click Compare to view the documents side by side in Compare Forms screen. Note: If you want to place a request for manual translation of your documents by our experienced translators, click at the top-right of the Forms screen. 61