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Tax Treaties
Bosnia Herzegovina
Bosnia and Herzegovina, following its 30 October 2019 signing of the Multilateral Convention (MLI), had published the list of expected reservations and notifications. Bosnia and Herzegovina's...
Rotfleisch & Samulovitch P.C.
During a post-fight interview in June 2020, Ultimate Fighting Championship (UFC) welterweight contender "Platinum" Mike Perry voiced his frustration about grappling with international tax rules.
Torys LLP
Managing remotely raises unique tax issues for businesses.
Bennett Jones LLP
The clock is ticking for multinational enterprises and private equity firms with investments in the Canadian resource sector as anti-treaty shopping measures in the OECD's ...
Osler, Hoskin & Harcourt LLP
On May 19, 2020, the IRS released long-awaited guidance providing comfort to taxpayers that the imminent replacement of NAFTA by the USMCA would generally not jeopardize a taxpayer's ability to rely on U.S. income tax treaty benefits.
Osler, Hoskin & Harcourt LLP
The global travel restrictions caused by the COVID-19 pandemic have resulted in some individuals involuntarily remaining in one jurisdiction or being unable to enter another jurisdiction.
Davies Ward Phillips & Vineberg
The emergence of COVID-19 in early 2020 has created significant global challenges, not the least of which include restrictions on the ability to travel between countries.
Rotfleisch & Samulovitch P.C.
Canada Revenue Agency levies income taxes on two bases. The first basis is on persons who have close ties to Canada – where such persons are residents of Canada.
Crowe MacKay LLP
In response to COVID-19, countries have imposed health measures and travel restrictions ("Travel Restrictions") to keep the global community safe.
Kinanis LLC
The last financial crisis changed the landscape around taxes throughout the world. The world has moved to greater transparency and additional measures were introduced in order to combat tax evasion and tax avoidance.
Kinanis LLC
As it is known already, the Russian Federation has sent an official notification to the Republic of Cyprus asking for the renegotiation of the Double Tax Treaty (DTT) agreement between the two countries.
On January 17th,2020, the double tax treaty between the Government of the Republic of Kazakhstan and Government of the Republic of Cyprus was ratified.
Oxford Management
It is well known that a Cyprus holding company has many tax advantages which are so great that they make it the absolute tool for international tax planning and optimization.
European Union
Cyprus and Switzerland, signed a protocol on Monday 21st July 2020, amending the existing double taxation agreement of 2014 intending to strengthen the framework of economic relations between the two countries.
Areti Charidemou & Associates LLC
Cyprus House of Representatives adopted on 19th June 2020 the law to implement the directive (EU Anti-Tax Avoidance Directive (ATAD EU 2016/1164) that will be applied retrospectively ...
Supreme Court holds Project Office undertaking non-core activities in India does not constitute Permanent Establishment
Khaitan & Co
The Supreme Court of India (SC) in Director of Income Tax-II (International Taxation) v M/S Samsung Heavy Industries Co. Ltd. (Civil Appeal No. 12183 of 2016)
King, Stubb & Kasiva
The Authority of Advanced Ruling (AAR), New Delhi dismissed the petition in the case of Tiger Global International II Holdings, Mauritius & Ors (Petitioner),
In a multinational framework, it is common that one of the group entities stand as surety / guarantor for another group entity or its subsidiary – Indian or otherwise, sometimes for a charge.
Kevin Shah & Associates
M/s. Brand Equity Treaties Ltd & many other judgments have allowed transitional ITC inspite of non-filing/incorrect filing of FORM GST TRAN-1 on the following grounds:
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