News & Analysis as of

Tax Treaty Double Taxation Organization for Economic Co-operation and Development

Cadwalader, Wickersham & Taft LLP

Burlington Loan Management DAC: Treaty Shopping Provisions Did Not Apply

The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more

Miller Nash LLP

Today in Tax: U.S. Tax Treaty Updates—Chile, Croatia, and Hungary

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more

A&O Shearman

Great Fund Insights: The new Luxembourg/United-Kingdom tax treaty has finally been signed!

A&O Shearman on

More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. ...more

Bracewell LLP

UAE and Israel Sign Tax Treaty

Bracewell LLP on

On Monday, 31 May 2021, the UAE and Israel signed a tax treaty in order to boost economic cooperation. It is expected that, following ratification later this year, the treaty will come into effect on 1 January 2022. The move...more

Goodwin

Luxembourg Tax Authority Issues New Guidance On Mutual Agreement Procedure

Goodwin on

On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more

Holland & Knight LLP

DIAN emite interpretación de Convenios para Evitar la Doble Tributación suscritos por Colombia

Holland & Knight LLP on

El 13 de diciembre de 2019 entró en vigor el Convenio para Evitar la Doble Tributación entre Colombia y el Reino Unido e Irlanda del Norte y su aplicación en materia de retenciones en la fuente será a partir del 1 de enero de...more

White & Case LLP

Belgian draft law ratifying the MLI: A new paradigm in international tax law

White & Case LLP on

On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more

Akin Gump Strauss Hauer & Feld LLP

UK ratifies the OECD’s Multilateral Instrument – Practical Impact and Timing of Implementation

On 23 May 2018, the United Kingdom ratified the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, otherwise known as the ‘Multilateral Instrument’ (“MLI”). The...more

Skadden, Arps, Slate, Meagher & Flom LLP

European Commission Presents ‘Fair Taxation of the Digital Economy’ Package

On March 21, 2018, the European Commission released a draft legislative package for “fair taxation of the digital economy,” which would establish new tax rules for digital business activities within the European Union. This...more

Jones Day

France and Luxembourg Sign New Tax Treaty

Jones Day on

The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...more

Orrick, Herrington & Sutcliffe LLP

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

Proskauer - Tax Talks

BEPS: Update on Action 6 on Treaty Benefits

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

Proskauer - Tax Talks

BEPS: OECD Releases Multilateral Tax Treaty Convention

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

Dechert LLP

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

Dechert LLP on

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

Dechert LLP on

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

Skadden, Arps, Slate, Meagher & Flom LLP

"OECD Outlines Plans to Prevent Double-Tax Treaty Abuse"

On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more

16 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide