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Results: 1-10 of 99

IRS increases scrutiny of inter-company debt arrangements

  • Landwell
  • -
  • USA
  • -
  • October 17 2011

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

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

  • Landwell
  • -
  • China, India, Pakistan, United Kingdom
  • -
  • 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

US tax treaty developments

  • Landwell
  • -
  • USA
  • -
  • October 17 2011

The Senate Foreign Relations Committee on July 26, 2011 approved the new US-Hungary tax treaty and protocols to the Luxembourg and Switzerland treaties, with the recommendation that all three pacts be approved

Portugal Luxembourg Double Tax Treaty

  • Landwell
  • -
  • Luxembourg, Portugal
  • -
  • 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

Tax deductibility of G&A expenses allocated by offshore parent company

  • Landwell
  • -
  • Taiwan
  • -
  • May 20 2011

Despite Taiwan tax regulations expressly providing that general and administrative ("G&A") expenses of a foreign head office may be allocated to its Taiwan branch based on various criteria, the tax office often challenges the adequacy of such allocations if the required supporting documentation is not in place or the foreign parent company is merely a paper company

UK South Africa double tax treaty - new protocol being introduced

  • Landwell
  • -
  • South Africa, United Kingdom
  • -
  • November 22 2011

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

Modifications of debt instruments T.D. 9513

  • Landwell
  • -
  • USA
  • -
  • April 27 2011

On 7 January 2011, the IRS published final regulations intended to clarify when and how a debt instrument should be retested for debt vs. equity status, and when its terms have been significantly modified

Proposed tax changes - Finance Bill 2011

  • Landwell
  • -
  • India
  • -
  • April 27 2011

India's Finance Minister announced India's Union Budget for the financial year 2011-12 on February 28, 2011 along with presentation of the proposed Finance Bill 2011

Discussion draft released for corporate rate reduction and territorial tax system

  • Landwell
  • -
  • USA
  • -
  • November 22 2011

On October 26, 2011, House Ways and Means Committee Chairman Dave Camp released for public comment a discussion draft on revenue-neutral corporate tax reform that lowers the top corporate tax rate to 25 and adopts a territorial tax system, generally effective for tax years beginning after 2012

2012 State Budget proposal

  • Landwell
  • -
  • Portugal
  • -
  • November 22 2011

On October 17, 2011, the Portuguese Government presented the 2012 State Budget proposal for Parliament’s discussion and further approval