Bennett Jones LLP
The FCA found that the object, spirit and purpose of the relevant Can-Lux Treaty provisions is reflected in the clear and simple text of the Treaty.
McCarthy Tétrault LLP
In Her Majesty the Queen v. Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal confirmed that so-called "treaty shopping" is not abusive of Canada's tax treaties.
Osler, Hoskin & Harcourt LLP
In Canada v Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal (FCA) confirmed there was no abusive tax avoidance under Canada's general anti-avoidance rule (GAAR) ...
Aird & Berlis LLP
The Federal Court of Appeal in Alta Energy1 held that the Appellant, a Luxembourg corporation, could properly rely on the Canada-Luxembourg Treaty.
On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy),
C.Savva & Associates Ltd
In 2013, G20 and the Organisation for Economic Co-operation and Development launched the Base Erosion and Profit Shifting Project, a global initiative aimed at preventing tax avoidance.
Cadwalader, Wickersham & Taft LLP
On 18 February, 2020, the Council of the European Union (the "EU Council") added the Cayman Islands to the EU's official list of non-cooperative jurisdictions, ...
On 18 February 2020, the ECOFIN committee of the European Union resolved to move the Cayman Islands to the EU's Annex I list of non-cooperative jurisdictions for tax purposes.
Les activités, réputées occultes au regard de la loi fiscale, placent leurs auteurs dans une situation très inconfortable face à l'administration fiscale.
Those initiating in covert activities under French tax law are in a very awkward position with regard to the tax authorities.
SKP Business Consulting LLP
Finance Minister in Budget 2020 has made some major changes to tax residency laws in India. The tax residency of a person was determined based on his/her stay in India (number of days).
Khaitan & Co
For the years in question, the Taxpayer did not file tax returns in India.
In a bold move aimed at increasing foreign investment, India has announced the withdrawal of its dividend distribution tax
While the Finance Bill 2020 seeks to enhance effectiveness, transparency and accountability of tax administration, the proposals (barring a few) are largely tepid.
Kochhar & Co.
The scope of income of a person liable to tax in India depends upon his residential status in a particular financial year.
SKP Business Consulting LLP
In a move to reduce the pending litigations, the Union Budget
2019 had proposed 'Sabka Vishwas'scheme under indirect
taxes. The said scheme turned out to be a huge success
This Tax Update covers the Commencement of Expat Tax, Final Carbon Offset Regulations, BGR: Relief in respect of Tax Treaties and Clarification on interpretation of "Group of Companies".
whether insufficiency of funds was not reasonably foreseeable, and therefore constitutes reasonable grounds for non-payment of employees tax, considered.
Ropes & Gray LLP
•International Tax Review: Leading Women in Tax Forum: Ropes & Gray is a sponsor of the ITR: Leading Women in Tax Forum on March 3 in New York,...
On January 31, 2020, the OECD reported significant steps in
advancing Pillar One, its approach for the taxation of the digital