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Mexico: Amendments to maquila rules will enter into force

David Cuellar Cesar Salagaray On June 30 2011, August 9 2011 and October 10 2011, modifications to the Miscellaneous Foreign Trade Rules were published in Mexico's official gazette. The tax effects for foreign principals (acting under a maquila structure in Mexico) have been a recurrent matter of discussion and analysis since its publication.

November 01 2011

France: Significant changes to the treatment of losses and capital gains on shares

Hélène Rives Alexa Lecoeur The Amended Finance Act for 2011 was voted after an unusually quick legislative process in September 2011. It contains two main measures for companies.

November 01 2011

Chile: Additional withholding tax applicable to the forgiveness of interest

Loreto Pelegrí Haro Trinidad Fernández Gurruchaga According to Article 59 No 1 of the Chilean Income Tax Law (ITL), interest remitted abroad is subject to additional withholding tax.

November 01 2011

Canada: Residence not a prohibited ground of treaty discrimination

Janette Pantry Rebecca Levi A recent decision of Canada's Federal Court of Appeal considered the non-discrimination provision of the Canada-UK Tax Convention finding that it did not apply because the Canadian domestic legislation in question discriminated based on residency rather than nationality. The Federal Court of Appeal confirmed that Canada is not prohibited under the treaty from discriminating against taxpayers based on their residency.

November 01 2011

Albania: Albania-Ireland tax treaty enters into force

Eylem Philippou Drilona Likaj The income tax treaty that was signed back in October 2009 for the avoidance of double taxation and prevention of fiscal evasion between Albania and Ireland entered into force on July 12 2011 and will be applicable from January 1 2012.

November 01 2011

The consequences of estimating assumed obligations

On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.

November 01 2011

Chile: Additional withholding tax applicable to the forgiveness of interest

According to Article 59 No 1 of the Chilean Income Tax Law (ITL), interest remitted abroad is subject to additional withholding tax.

November 01 2011

India: Taxability of procurement activities undertaken by a liaison office

The Authority for Advance Rulings (AAR) in the case of Columbia Sportswear Company [2011-TII-21-ARA-INTL], adjudicated on the taxability of procurement activity undertaken by a non-resident company through its liaison office (LO) in India.

November 01 2011

Montenegro: Montenegro to maintain competitive tax system

Sead Dado Salkovic To prevent consequences similar to those in the European countries regarding current debt crisis, the Montenegrin government plans to implement a number of economic measures by the end of the year, which will mostly concern public sector spending.

November 01 2011

FYR Macedonia: Kosovo treaty

Elena Kostovska In April, FYR Macedonia signed a treaty for the avoidance of double taxation with its newest neighboring state, Kosovo. The two countries have recently made steps toward boosting the cross-border economic cooperation, with multiple joint projects, activities as well as meetings between the chambers of commerce. In 2010, the total exchange between the two countries increased by 41% and FYR Macedonia's exports to Kosovo are estimated at a significant amount of $300 million.

November 01 2011

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