After years of debate, delay and controversy, the US has signed its double tax treaty with Venezuela. It is the first between the US and a Latin American country outside of NAFTA members. The treaty breaks new ground as Venezuela, like many other Latin American jurisdictions, has a territorial tax system. The hope is that the precedent set will be followed throughout the region.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
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