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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

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

Critical IRS policy change regarding processing and filing deadline to carryback 2010 net operating losses

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

The ability for corporate taxpayers to obtain a quick refund by filing IRS Form 1139, Corporation Application for Tentative Refund, is important and can quickly increase a corporation’s cash flow in today’s difficult economy

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

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

Update on double tax treaties

  • Landwell
  • -
  • Singapore, Uzbekistan
  • -
  • November 22 2011

The protocol to the treaty with Uzbekistan, which incorporates the internationally agreed Standard for the Exchange of Information (EOI) into the treaty, has been ratified and will take effect from November 1, 2011

Double tax treaties

  • Landwell
  • -
  • China, Nepal, Turkmenistan
  • -
  • April 27 2011

This Double Tax Treaty ( DTT ) and its protocol, concluded on May 14, 2001, entered into force on December 31, 2010 and are effective in relation to income derived in and after the tax year starting from January 1, 2011

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

Report of Foreign Bank and Financial Accounts “FBAR” new rules expand the number of officers and employees required to file by June 30, 2011

  • Landwell
  • -
  • USA
  • -
  • May 20 2011

New regulations effective March 29, 2011, can affect a significant number of US persons with a financial interest in, or signature authority over, foreign financial accounts reported on the Form TD F 90-22, Report of Foreign Bank and Financial Accounts, commonly referred to as FBAR

Treaty update

  • Landwell
  • -
  • Hong Kong
  • -
  • April 27 2011

A new DTT with Hong Kong, signed on June 22, 2010, came into force on February 10, 2011 and will be effective from January 1, 2012