News & Analysis as of

Tax Treaty Withholding Tax

Investor-Friendly Tax Treaty Set for Mexico and Spain

by Jones Day on

The Situation: A Tax Treaty developed to avoid double taxation, negotiated between Mexico and Spain in late 2015, was just recently published in the official gazettes of both nations. The new protocols are effective September...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

Google Ireland Limited does not have permanent establishment in France

The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010. The Irish company Google Ireland Limited sells digital...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

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

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

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

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

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

UK Finance Bill 2016: Royalty Withholding Tax

by DLA Piper on

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

LLCs May Be Right Unless They’re Wrong

by Arnall Golden Gregory LLP on

As I’ve posted before, I usually advise non-US companies to form a corporation when expanding to the United States. Every now and then, I get some pushback because the non-US company has heard about ‘limited liability...more

2016 Federal Budget – Selected Tax Measures

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 Federal Budget (the 2016 Budget). This was the first budget presented by the newly-elected Liberal government, which won a strong majority in the fall 2015...more

European M+A News, Winter 2016

by Morrison & Foerster LLP on

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

by Shearman & Sterling LLP on

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

2013 Amendments to United States and Japan Income Tax Treaty

by Baker Donelson on

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

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