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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


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 Treaty with Barbados enters into force
  • Landwell
  • Barbados, Luxembourg
  • November 22 2011

The Double Tax Treaty between Luxembourg and Barbados has been ratified and has entered into force


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


Treaty updates
  • Landwell
  • Singapore, Ireland
  • May 20 2011

Ireland signed a Double Tax Treaty with Singapore on October 28, 2010 which came into force on April 8, 2011 and is effective from January 1, 2011


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


Germany-Hungary
  • Landwell
  • Germany, Hungary
  • April 27 2011

On February 28, 2011, Germany and Hungary signed a revised agreement (Revisionsabkommen


Germany-Cyprus
  • Landwell
  • Cyprus, Germany
  • April 27 2011

Germany signed a new Double Tax Treaty with Cyprus on February 18, 2011