We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 99

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


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


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


Draft Assessment Rule for Thin Capitalization
  • Landwell
  • Taiwan
  • May 20 2011

The "thin capitalization rule" was introduced in an amendment to the Taiwan Income Tax Act ("ITA") in January 2011


Release of the “administrative measures for overseas registered Chinese-capital controlled Tax Resident Enterprises (Trial)”
  • Landwell
  • China
  • October 17 2011

The new PRC Corporate Income Tax Law which took effect from January 1, 2008 introduced the concept of Tax Resident Enterprise


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


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


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

A new protocol introduces an exchange of information clause to this treaty


Foreign company must file return for nontaxable taxable share transfer under treaty
  • Landwell
  • India, Netherlands
  • May 20 2011

The Authority for Advance Rulings ("AAR") recently ruled that a foreign company was required to file an India income tax return, even though no income was subject to tax in India as a result of an exemption under the India-Netherlands treaty