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Tax Treaties
Bosnia Herzegovina
Bosnia and Herzegovina, following its 30 October 2019 signing of the Multilateral Convention (MLI), had published the list of expected reservations and notifications. Bosnia and Herzegovina's...
Osler, Hoskin & Harcourt LLP
On May 19, 2020, the IRS released long-awaited guidance providing comfort to taxpayers that the imminent replacement of NAFTA by the USMCA would generally not jeopardize a taxpayer's ability to rely on U.S. income tax treaty benefits.
Osler, Hoskin & Harcourt LLP
The global travel restrictions caused by the COVID-19 pandemic have resulted in some individuals involuntarily remaining in one jurisdiction or being unable to enter another jurisdiction.
Davies Ward Phillips & Vineberg
The emergence of COVID-19 in early 2020 has created significant global challenges, not the least of which include restrictions on the ability to travel between countries.
Rotfleisch & Samulovitch P.C.
Canada Revenue Agency levies income taxes on two bases. The first basis is on persons who have close ties to Canada – where such persons are residents of Canada.
Crowe MacKay LLP
In response to COVID-19, countries have imposed health measures and travel restrictions ("Travel Restrictions") to keep the global community safe.
Gowling WLG
As a consequence of COVID-19, governments and businesses around the world have introduced travel restrictions to protect their citizens and employees.
Davies Ward Phillips & Vineberg
Earlier this year, Parliament enacted legislation adopting the Canada Emergency Wage Subsidy (CEWS) through amendments to the Income Tax Act (Canada) (Act).
McCarthy Tétrault LLP
On May 22nd, 2020, the Canada Revenue Agency ("CRA") released guidance (the "Guidance") on how it will deal with certain international tax issues that have arisen as a result of the travel restrictions ("Travel Restrictions"), or ...
Kinanis LLC
The last financial crisis changed the landscape around taxes throughout the world. The world has moved to greater transparency and additional measures were introduced in order to combat tax evasion and tax avoidance.
Kinanis LLC
As it is known already, the Russian Federation has sent an official notification to the Republic of Cyprus asking for the renegotiation of the Double Tax Treaty (DTT) agreement between the two countries.
On January 17th,2020, the double tax treaty between the Government of the Republic of Kazakhstan and Government of the Republic of Cyprus was ratified.
Oxford Management
It is well known that a Cyprus holding company has many tax advantages which are so great that they make it the absolute tool for international tax planning and optimization.
In a multinational framework, it is common that one of the group entities stand as surety / guarantor for another group entity or its subsidiary – Indian or otherwise, sometimes for a charge.
Kevin Shah & Associates
M/s. Brand Equity Treaties Ltd & many other judgments have allowed transitional ITC inspite of non-filing/incorrect filing of FORM GST TRAN-1 on the following grounds:
Mutual Agreements Procedure (MAP) is a model or mechanism available to taxpayers to resolve disputes that have arisen due to double taxation.
In a recent Ruling, Authority for Advance Ruling (AAR) denied DTAA benefit in respect of indirect transfer of shares.
Khaitan & Co
Between October 2011 to April 2015, the Applicants invested in the shares of Flipkart Private Limited, a company incorporated in Singapore (Flipkart).
Khaitan & Co
The tax officer however held that Guarantee Money paid to non-resident sports association is in relation to the matches played in India and attracts withholding of tax under section 194E of the IT Act.
Khaitan & Co
The Supreme Court of India in Union of India & Anr v UAE Exchange Centre, held that the liaison office set up by UAE Exchange Centre LLC in India does not constitute its permanent establishment in India.
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