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Results: 1-10 of 101

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


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


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


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


Cost plus method by PE for R&D is at arm’s length
  • Landwell
  • Belgium
  • April 27 2011

The Belgian Ruling Commission published an advance ruling on the application of a cost plus method by a Belgian PE carrying out a limited R&D activity in Belgium for group companies


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


Budget 2011
  • Landwell
  • Singapore
  • April 27 2011

The 2011 Budget was announced on February 18, 2011


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