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Portugal Luxembourg Double Tax Treaty

Landwell
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Luxembourg, Portugal
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April 27 2011

On February 24, 2011, the Portuguese Council of Ministers approved the proposal of a resolution that approves the protocol amending the DTT signed between Portugal and Luxembourg

Court of Appeal issues decision in respect of M&S cross-border loss relief case

Landwell
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European Union, United Kingdom
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November 22 2011

The ECJ issued a judgement on this case, concerning cross-border loss relief claimssurrenders, in 2005 but the UK courts are still considering the details of how to apply these principles

New rules for non-resident investment in portfolio investment entities

Landwell
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New Zealand
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May 20 2011

Parliament has proposed amendments to the Taxation (Tax Administration and Remedial Matters) Bill which introduce new tax rules for non-resident investors in portfolio investment entities (PIEs

Clarification of corporate income tax treatment of certain passive income and equity transfers by non-tax resident enterprises

Landwell
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China
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May 20 2011

On March 29, 2011, the State Administration of Taxation ("SAT") issued a circular (Public Notice 2011 No.24) to clarify the taxation of certain income (mainly passive income) derived in China by non-tax resident enterprises (“Non-TREs”), including accrued payments due to Non-TREs, guarantee fees, capital gains from the transfer of land use rights in China, rental from financial leases or leases of immovable property in China, dividends and profit distributions, etc

The latest interpretation of the Technical Service Fees article under relevant Double Tax Treaties concluded by China

Landwell
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China, India, Pakistan, United Kingdom
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May 20 2011

There are a few Double Tax Treaties ("DTTs") concluded by China, namely the DTTs with UK, India and Pakistan (referred as "relevant DTTs" hereafter), which include a specific article on Technical Service Fees

Portugal Turks and Caicos Tax Information Exchange Agreement

Landwell
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Portugal, Turks & Caicos Islands
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April 27 2011

On February 24, 2011, the Portuguese Council of Ministers approved the proposal of a resolution that approves the agreement signed between Portugal and the Turks and Caicos on December 21, 2010

IRS increases scrutiny of inter-company debt arrangements

Landwell
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USA
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October 17 2011

The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility

UK South Africa double tax treaty - new protocol being introduced

Landwell
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South Africa, United Kingdom
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November 22 2011

South Africa is changing its system of taxing dividends paid to non-residents and introducing withholding tax (WHT

ECJ decides on Portuguese legislation on nonresident pension funds taxation

Landwell
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European Union, Portugal
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November 22 2011

On October 6, the European Court Of Justice (ECJ), issued its decision on the procedure brought forward on December 1, 2009 by the European Commission (EC) against the Portuguese Republic (Case C-49309

2012 Tax Package

Landwell
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Netherlands
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November 22 2011

On September 15, 2011, the Dutch government published the 2012 Tax Package

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Search results

Portugal Luxembourg Double Tax Treaty

Court of Appeal issues decision in respect of M&S cross-border loss relief case

New rules for non-resident investment in portfolio investment entities

Clarification of corporate income tax treatment of certain passive income and equity transfers by non-tax resident enterprises

The latest interpretation of the Technical Service Fees article under relevant Double Tax Treaties concluded by China

Portugal Turks and Caicos Tax Information Exchange Agreement

IRS increases scrutiny of inter-company debt arrangements

UK South Africa double tax treaty - new protocol being introduced

ECJ decides on Portuguese legislation on nonresident pension funds taxation

2012 Tax Package

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