USA - October 17 2011 The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility.
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.
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.
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.
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).