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Results: 1-10 of 99

UK South Africa double tax treaty - new protocol being introduced
  • Landwell
  • South Africa, United Kingdom
  • November 22 2011

South Africa is changing its system of taxing dividends paid to non-residents and introducing withholding tax (WHT


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


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


Portugal Panama Double Tax Treaty
  • Landwell
  • Panama, Portugal
  • April 27 2011

On February 24, 2011, the Portuguese Council of Ministers approved the proposal of a resolution that approves the DTT signed between Portugal and Panama on August 27, 2010


IRS releases guidance on Schedule UTP and policy of restraint
  • Landwell
  • USA
  • April 27 2011

The IRS on 23 March released guidance in the form of answers to several frequently asked questions (FAQs) raised by taxpayers and practitioners with respect to reporting "uncertain tax positions" on the final Schedule UTP and earlier guidance, which the IRS had issued in September 2010


Inbound structuring: some amendments to Ghana’s tax laws
  • Landwell
  • Ghana
  • April 27 2011

Following parliamentary approval of the Government's budget statement for 2011, the Government of Ghana has made some amendments to Ghana's tax laws