June 2018
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International Correspondents
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Sponsored by KPMG USMark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017. -
Sponsored by MathesonThe Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish tax credit was claimed for part of the foreign tax withheld. The decision is being appealed to the High Court.
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Sponsored by PwC ChileOver the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.
