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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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap