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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


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


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


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


Double Tax Treaty with Panama enters into force
  • Landwell
  • Luxembourg, Panama
  • November 22 2011

The Double Tax Treaty between Luxembourg and Panama has been ratifi ed and has entered into force


IRS emphasis on partnership audits
  • Landwell
  • USA
  • November 22 2011

Information published by the IRS shows a major change in the types of tax returns companies are fi ling due to changes in their business structures


Ireland United Arab Emirates - Double Tax Treaty
  • Landwell
  • Ireland, United Arab Emirates
  • November 22 2011

The United Arab Emirates - Ireland Double Tax Treaty, which was signed on July 1, 2010, has been ratified


Spain treaty updates
  • Landwell
  • Spain
  • November 22 2011

The tax treaty that Spain signed with Panama in Madrid on October 7, 2010, entered into force on July 25, 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


Protocol signed amending the DTA between China and Latvia
  • Landwell
  • China, Latvia
  • November 22 2011

A protocol amending the Agreement between the Government of the Public Latvia and the Government of the People’s Republic of China for the Avoidance of Double Taxation (DTA) and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital was concluded on August 24, 2011 and will enter into force after the completion of ratifi cation and notifi cation by both countries