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Results: 1-10 of 99

WHT on payments for the right to use industrial equipment - scope limited by national court

  • Landwell
  • -
  • Poland
  • -
  • April 27 2011

Polish CIT Law obliges a Polish tax resident to deduct 20 WHT (unless lower rate provided by a DTT or implementation of Interest-Royalties Directive applies) from a payment made to a non-Polish entrepreneur for use or right to use of industrial equipment

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

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

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

ECJ decides on Portuguese legislation on nonresident pension funds taxation

  • Landwell
  • -
  • European Union, Portugal
  • -
  • 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

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

  • Landwell
  • -
  • China
  • -
  • 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

New rules for non-resident investment in portfolio investment entities

  • Landwell
  • -
  • New Zealand
  • -
  • 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

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

Brazilian Government changes IOF rules yet again

  • Landwell
  • -
  • Brazil
  • -
  • May 20 2011

With the aim of stemming speculative short-term investment and the depreciation of the U.S. Dollar against the Brazilian Real, the Brazilian Government has adopted new fiscal measures

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