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  • Sead Dado Salkovic The treaty for the elimination of double taxation with respect to taxes on income between Malta and Montenegro was concluded on November 4 2008. Further to its ratification, the treaty entered into force on September 23 2009, and became effective from January 1 2010.
  • Elena Kostovska The last months of 2009 brought in changes to the FYR Macedonian law on VAT. Both VAT registered and non-registered companies will find that the law may affect them, either by the introduction of different registration deadlines, VAT submission statements, and changes to the transfers of assets VAT treatment or VAT reductions in certain real estate sales.
  • Eric Roose Takeo Mizutani Foreign investors purchasing real estate in Japan directly through a Japanese company can expect to pay an effective tax rate of as much as 54% on repatriated earnings and gains. To reduce these very high rates of taxation, foreign investors in Japan generally invest through one of two structures, the Tokutei Mokuteki Kaisha (TMK) structure or the Tokumei Kumiai (TK) structure.
  • Nélio Weiss Philippe Jeffrey With the enactment of new thin capitalisation rules at the end of December 2009, many Brazilian entities will be forced to review their financing structure and find alternatives to counteract the potential loss of a portion of their current interest tax deduction. Under the new rules, the amount of debt granted by related parties cannot exceed twice the amount of the participation in the net equity of the Brazilian entity (2:1 ratio). For debts with entities located in a tax haven or favourable tax regime jurisdiction, the amount of debt cannot exceed 30% of the Brazilian entity's net equity.
  • Sabrina Wong Josh Jones The fifth protocol to the Canada-US income tax convention (the treaty) introduced a rule in article IV(6), generally effective for years beginning after 2008, relating to fiscally transparent entities, most notably US limited liability corporations (LLCs). Interpreting this rule has caused considerable confusion.
  • Following the highly contentious battle over health legislation and its subsequent enactment on March 23, President Obama on March 30 signed into law a health care reconciliation package including significant new tax provisions.
  • The Indian Central Board of Direct Taxes has issued instructions to the country's tax authorities on how to handle losses on foreign exchange derivatives.
  • A monthly commentary on the notable facts, figures and goings-on in the tax world.
  • The Greek government has submitted an updated tax bill to parliament after the European Commission ruled that the country infringed European procedures.