LATEST ARTICLES
Australia
Vincent Young
The Foreign Acquisitions and Takeovers Fees Imposition Amendment Bill 2024 (Fees Imposition Bill) and Treasury Laws Amendment (Foreign Investment) Bill 2024...
Alvarez & Marsal
In this article, we provide an overview of the OECD Pillar 2 framework and the current status of the rules in Australia, and discuss some of the key implications and challenges...
Alvarez & Marsal
The Australian Taxation Office (ATO) issued a new draft taxation ruling (TR 2024/D1) on 17 January 2024 in relation to the character of receipts...
Fortis Accounting Partners
A skilled international tax expert would help businesses reduce risks and develop effective tax planning strategies.
Herbert Smith Freehills
The ATO has released a new Taxpayer Alert [TA 2022/2] on treaty shopping arrangements, in particular: "arrangements designed to obtain the benefit of a reduced withholding tax … rate …
China
Hawksford
Dividend repatriation is one of the main methods used by overseas shareholders for retrieving funds from Chinses investments, given the jurisdiction's foreign exchange controls.
Hong Kong
Mayer Brown
The times are changing. Due to pressure from the European Union, Hong Kong has issued the framework of how it proposes to change its long-cherished offshore taxation rules applicable to passive...
Mayer Brown
Due to pressure from the European Union, the Hong Kong government is proposing to change the offshore tax regime for the taxation of foreign dividends, interest income, royalty income and...
PKF
The unprecedented change in the economic environment following the outbreak of COVID-19 has given rise to new restrictions imposed by governments around the world...
India
Parakram Legal
In a recent ruling, the Income Tax Appellate Tribunal, Delhi recognized and upheld the importance of the Tax Residency Certificate and held that a Mauritius-based Collective Investment Vehicle registered as a Foreign Portfolio Investor …
The Sovereign Group
The governments of India and Mauritius signed, on 13 March, a second amending protocol to the 1982 double tax agreement (DTA) between the two countries...
Nishith Desai Associates
2023 was a year of unexpected headwinds, such as the hiking of interest rates by governments across the world, the banking sector instability in the US and Europe, the Russia-Ukraine and Israel-Hamas conflict, to name a few.
Lakshmikumaran & Sridharan
The Indian domestic tax laws contain certain provisions which provide differential tax treatment in transactions involving residents and non-residents.
S&R Associates
The primary purpose of double taxation avoidance agreements ("DTAAs") is to eliminate double taxation by providing taxing rights or granting tax credit...
Majmudar & Partners
The Gujarat High Court (the "HC"), in a recent ruling (the "HC Ruling"), dismissed the Indian tax department's (the "ITD") appeal against a Tribunal Ruling allowing the taxpayer...
Lakshmikumaran & Sridharan
Revenues earned by MNCs from India often remain under the lens of the Indian taxation authorities for examination of constitution of Permanent Establishment...
Acuity Law
Indirect transfer controversy has been the most discussed issue in the Indian tax ecosystem. It began when Vodafone International Holdings Ltd acquired an indirect holding in an Indian entity...
Japan
Anderson Mori & Tomotsune
Under Japanese tax law, in brief, an individual's tax residency status and the source of income affects a range of taxation imposed on such Individual.
Kyrgyzstan
GRATA International
In the contemporary period, there is an increasing demand for qualified specialists in different sectors of the economy of the Kyrgyz Republic. Taking into consideration that various legal issues...
GRATA International
The Protocol on Amendments to the Treaty on the Eurasian Economic Union dated May 29, 2014, signed on February 8, 2021 in Moscow, provides for amendments to the Protocol on the procedure...
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