The Brazilian tax authorities issued on December 23 2004 the Interpretation Declaratory Act (ADI 27, which is an official interpretation from the Brazilian tax authorities), setting forth their understanding in connection with payments of dividends, royalties and service fees made under the Brazil-Spain Convention for the Avoidance of Double Taxation (the Tax Treaty)
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
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Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR