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Tax Treaties
Canada
TaxChambers LLP
As we commence the new year (2020), we prepare ourselves for what awaits us: spring showers, flowers, and the hand of the tax collector reaching into our pockets.
Davies Ward Phillips & Vineberg
In a case argued by Davies, the Court of Québec rendered a judgment on December 10 setting out, for the first time, the conditions that must be met for the electronic disclosure of evidence by the Crown to be "reasonably accessible", ...
European Union
Ropes & Gray LLP
Digital Taxation - Implications for EU Technology Companies.
France
Fieldfisher LLP
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 ...
Velvet Avocats
Denmark has no longer been bound by any tax treaty with France since 2009.
Germany
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).
India
Nangia & Co
The Income Tax Appellate Tribunal, Cochin ruled that Short Term Capital Gains earned by Sri K.E. Faizal (assessee) through alienation of units of ‘equity oriented mutual funds' are not taxable in India in view of ...
Shah V G & Co.
Movement of expatriates cross borders potentially creates several tax and regulatory issues.
DNV & Co
In our general understanding, in any international transaction, ‘Business Income' of an Enterprise is taxed in the country of its Residence unless the company has a ‘Permanent Establishment' in another country ...
AZB & Partners
The interest payable to a non-resident by an Indian borrower is taxable in the hands of such non-resident in India ...
Ireland
Maples Group
1.1 How many income tax treaties are currently in force in your jurisdiction? As of September 2019, 74 treaties have been signed, 73 of which are in force.
Luxembourg
ATOZ Tax Advisers
The world of alternative investment funds was not the primary target of the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) norms.
Malta
CSB Group
Substance has become a key term when setting up a new corporate structure, in international tax planning and in restructuring of existing corporate structures.
Netherlands
Dentons
On March 5, 2019, the Upper House (Eerste Kamer) of the Dutch parliament approved the Multilateral Convention to implement tax treaty-related measures to combat base erosion
Nigeria
Andersen Tax LP
The Federal Inland Revenue Service (FIRS) recently issued a Public Notice informing the general public of its Circular No: 2019/03 on the Claim of Tax Treaties Benefits in Nigeria (the Circular).
UK
Vistra
The UK's Brexit plans continue in 2020, but there are now some welcome elements of certainty for the UK and international business following the UK's decisive general election result.
Ukraine
Dentons
Dividends are subject to a 5% tax rate if the beneficial owner of the dividends is a company (other than a partnership) which:
United States
Gibson, Dunn & Crutcher
The United Kingdom's withdrawal from the European Union could have a significant effect on international and U.K. domestic taxation. It will likely impact aspects of the United Kingdom's value
Worldwide
Soteris Pittas & Co LLC
On May 30th, 2018, the successful final round of negotiation within the conclusion of the negotiation of the Convention for the Avoidance of Double Taxation and the Prevention of Tax...
China Tax & Investment Consultants Ltd
The 2015 Final Report on action 7 of the OECD/G20 BEPS Action Plan, titled "Preventing the Artificial Avoidance of Permanent Establishment Status", addresses the issue of artificial avoidance of permanent establishment status, ...
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