We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

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

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

Draft tax treaty anti-avoidance legislation withdrawn

  • Landwell
  • -
  • United Kingdom
  • -
  • October 17 2011

Draft legislation was published on August 1, 2011, intended to stop individuals, companies and other persons benefi tting from the provisions of a double taxation agreement where the claim is part of an arrangement the main purpose of which is to reduce a liability to UK tax

Temporary reestablishment of the wealth tax

  • Landwell
  • -
  • Spain
  • -
  • November 22 2011

On September 6, Spain enacted Royal Decree- Law 132011 re-establishing temporarily the wealth tax, which has not been levied since 2007

Double tax treaty - Armenia Ireland

  • Landwell
  • -
  • Armenia, Ireland
  • -
  • October 17 2011

Ireland signed a double tax treaty with Armenia on July 14, 2011

President Obama proposes $467 billion in tax increases to offset cost of jobs bill

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

President Barack Obama on September 12, 2011 sent to Congress legislative language and analysis for the $447 billion American Jobs Act that he proposed the week earlier, asking Congress to adopt the $467 billion in revenue raisers that would more than offset the cost of the package

Deduction on dividends received - abolishment of fixed financial asset condition

  • Landwell
  • -
  • Belgium
  • -
  • April 27 2011

Under Belgian corporate income tax law, Belgian taxpayers can, under conditions, benefit from a 95 deduction on dividends received ( DRD

Commitment to tax rate at 12.5

  • Landwell
  • -
  • Ireland
  • -
  • April 27 2011

Following the recent Irish election, and despite the large amount of press coverage, the new Prime Minister of Ireland has recently reaffirmed with other leaders in the European Union the new Government's commitment to the 12.5 corporation tax rate

Foreign company must file return for nontaxable taxable share transfer under treaty

  • Landwell
  • -
  • India, Netherlands
  • -
  • May 20 2011

The Authority for Advance Rulings ("AAR") recently ruled that a foreign company was required to file an India income tax return, even though no income was subject to tax in India as a result of an exemption under the India-Netherlands treaty