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Tax Treaty

IRS Announces Tax Treaties Resulted in Low Withholding Rates to Foreign Individuals and Entities

In the 2017 Statistics of Income Bulletin, the IRS reported that foreign recipients of U.S. source income from treaty countries had an average withholding rate of 13.9% compared to 25.6% for payments made to residents of...more

Extensions to the double tax treaty passport scheme

by DLA Piper on

The double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under...more

Bank of Italy Smooths the Path for Direct Debt Investment into Italy via EU Alternative Investment Funds

by McDermott Will & Emery on

International investment funds are set to benefit from measures issued by the Bank of Italy, aimed at facilitating direct investment into the country by EU alternative investment funds....more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada (Ukrainian)

by Dentons on

On 14 March 2017 the Ukrainian Parliament passed two laws for On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

Ukraine ratifies the Double Tax Treaty with Luxembourg and a Free Trade Zone Agreement with Canada

by Dentons on

On 14 March 2017 the Ukrainian Parliament passed two laws for ratification of two important international treaties...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

The Walking Dead - Using Private Placement Variable Deferred Annuity Contracts to Enhance the Investment Return in Life Settlement...

by Gerald Nowotny on

Overview - I have always been a film fan. Growing up in the Panama Canal Zone, one of my Mother’s jobs for the Panama Canal Company was serving as the manager of the Balboa Theater. We used to watch initial screenings of...more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

by Dentons on

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

BEPS: Update on Action 6 on Treaty Benefits

by Proskauer - Tax Talks on

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

Application of the concept of the person beneficially entitled to (beneficial owner of) income

by Dentons on

Dentons’ Russia Tax practice would like to remind that, starting from 1 January 2017, the procedure for confirming entitlement to tax benefits under relevant double tax treaties when paying income to foreign companies from...more

From Israel to Canada: New Tax Treaty to Help Structure Investments

On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions...more

Amendment Protocol to the India-Singapore Tax Treaty Inked

by Morgan Lewis on

Capital gains on alienation of shares to be taxable by India. The India-Mauritius tax treaty was amended by way of a protocol signed by the two countries on May 10, 2016—marking a landmark shift in India’s taxation...more

It’s a Wrap – The Year in India That Was

by Morgan Lewis on

Key developments in the Indian legal landscape in 2016 - From the Startup India campaign launched in January 2016 to the coming into force of substantial provisions of the Insolvency and Bankruptcy Code in December 2016,...more

India and Cyprus Enter into New Tax Treaty

by Morgan Lewis on

On November 18, India and Cyprus signed a revised agreement for the avoidance of double taxation and prevention of fiscal evasion. Per a November 18 press release issued by the Indian government, the revised agreement...more

BEPS: OECD Releases Multilateral Tax Treaty Convention

by Proskauer - Tax Talks on

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by the Organisation for Economic Co-operation and Development (“OECD”) on...more

"Double Trouble": The Kenyan Constitution and DTAs

by Dentons on

Controversy stalks international corporate taxation. With the integration of national economies and the promotion of Foreign Development Investments (FDIs), international corporations’ presence in multiple jurisdictions with...more

Post-Election Congress Returns for Lame Duck Session What to Expect? - Updated

by Mintz Levin - ML Strategies on

Last week, ML Strategies shared our thoughts on what to expect in the post-election lame duck Congress. The unknown factor at that point in time was who would be elected President on November 8th, which party would be in the...more

Recent EU and Luxembourg anti-BEPS developments extending to third countries

by DLA Piper on

EU Commission's ATAD proposal released On 25 October 2016 the EU Commission presented yet another package of corporate tax reforms comprising, inter alia, a proposal on tackling "hybrid mismatches" between the tax...more

U.S.-India Newsletter - Vol. 2016, Issue 3

by Pepper Hamilton LLP on

Summer 2016 was a season of change. In Europe, we saw the "Brexit," with the United Kingdom voting to withdraw from the European Union. The June referendum sent shockwaves through the business and finance communities and...more

Recent Changes to the India-Mauritius Tax Treaty: What Does This Mean for American Investors?

by Pepper Hamilton LLP on

The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more

India-Mauritius Protocol Seeks to Close Tax Loopholes

by K&L Gates LLP on

Originally published in The Investment Lawyer, Volume 23, Number 9, pages 19–27, September 2016. On May 10, 2016, the Republic of India and the Republic of Mauritius entered into a protocol (the ...more

Indian Government Approves New India-Cyprus Tax Treaty

by Perkins Coie on

The Indian government approved a new India-Cyprus tax treaty on August 24, 2016 that will allow the Indian government to tax capital gains on investments routed through Cyprus. This is part of a continuing campaign by the...more

Brexit – The UK and International Tax Consequences

by Dechert LLP on

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Tax Newsletter - March / April 2016 (China and Hong Kong)

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC, an...more

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