On February 12, 2020, in Canada v Alta Energy Luxembourg S.A.R.L. (2020 FCA 43), the Federal Court of Appeal ("FCA") unanimously held that the general anti-avoidance rule ...
Miller Thomson LLP
Subsection 107(2) of the Income Tax Act generally provides for a tax-deferred rollout of capital property held by the trustees of a Canadian-resident personal trust to their capital beneficiaries in satisfaction of their capital interests in the trust.
Rotfleisch & Samulovitch P.C.
Section 261 of Income Tax Act generally requires amounts reported on Canadian tax returns and other tax filings be reported in Canadian currency.
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),
A. Danos & Associates LLC
Cyprus and India signed on the 18th of November 2016 the revised double tax treaty between the two countries and a protocol that will allow India to tax capital gains in India.
Elias Neocleous & Co LLC
On 17 January 2020 the Cyprus-Kazakhstan double tax treaty (the agreement) entered into force.
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.
The Cyprus IP Box Regime applies on Qualifying IP's which are developed after the 1st of July 2016.
Cadwalader, Wickersham & Taft LLP
The United Kingdom left the EU on 31 January 2020.
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.
Ropes & Gray LLP
Digital Taxation - Implications for EU Technology Companies.
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.
Depuis quelques jours, nous sommes amenés à nous interroger, dans le sillage de l'agitation générée par le Consortium international de journalistes d'investigation concerné et de ses communications ...
P+P Pollath + Partners
On 10 December 2019, the Federal Ministry of Finance published a draft bill for a law to implement the Anti Tax Avoidance Directive (ATAD-Umsetzungsgesetz - ATADUmsG).