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  • The Constitutional Chamber of the Supreme Justice Tribunal in Venezuela has dismissed the motion for nullity filed by attorneys Fermín Toro Jiménez and Luis Britto García against the agreement for the avoidance of double taxation between the US and Venezuela. The National Investment Promotion Council (CONAPRI) defended the action, with counsel from law firm Torres Plaz & Araujo.
  • A ruling by Germany's highest tax court in May of this year compels the German tax authorities to rethink their proposed transfer pricing documentation regulations. By Alexander Vögele and William Bader, KPMG, Frankfurt
  • Certain guiding principles need to be followed when interpreting the provisions of a double taxation treaty vis-à-vis domestic tax law. This article considers the international context set out by article 9 of the OECD model, and its application to Indian domestic law. By Vispi Patel, Deloitte Haskins & Sells Mumbai
  • Norton Rose makes its presence felt in Germany
  • UK internet service provider Freeserve has hit out at US rival AOL for failing to charge value-added tax (VAT) on its flat rate internet package.
  • Linklaters and leading Brazilian law firm Goulart Penteado, Iervolino e Lefosse ? Advogados (GPIL) have entered into a cooperation agreement to provide legal advice for both Brazilian and international clients.
  • In the 25 years since the current UK-US tax treaty was signed, significant changes have taken place in the world of international taxation. The long-awaited overhaul is now complete, creating short-term uncertainty, but bringing a promise of less than a quarter of a century until the next update. By Chris Harrison and Dave Lewis, Allen & Overy, London
  • The IRS experiences a significant setback in its efforts to combat so-called corporate tax shelters and alleged abusive transactions, unexpectedly concedes the inclusion of stock options in cost sharing pool in Seagate, and has acquiesced on the UK petroleum revenue tax in Exxon v Commissioner. By Hal Hicks, David Benson and Margaret O’Connor, Washington DC
  • China’s government is signaling its emphasis on tax law enforcement in its New Law. Companies may want to make sure their tax affairs are in good order. By Yunfang Wendy Guo, KPMG’s International Chinese Tax Center of Excellence, New York
  • Chile recently introduced new tax law provisions. Whilst foreign institutional investors gain an exemption, a new thin capitalization rule along with limitations on certain taxplanning techniques show the authorities’ more stringent approach to the subject of tax avoidance. By Leon Larrain and Miguel Zamora, Baker & McKenzie, Santiago