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  • A number of recent rulings in India have denied treaty relief to residents of low-tax jurisdictions. Frank D’Souza, Keyur Shah and Jatin Goradia of Arthur Andersen in Mumbai examine the consequences for other double tax agreements signed by India
  • Under Austrian national law, payments made to non-resident artists and sportsmen for their cultural or sporting activities in Austria are subject to a 20% withholding tax. Recently, the Austrian Ministry of Fiscal Affairs issued new guidelines for the income taxation of non-resident artists and sportsmen. The cornerstones of these new guidelines are the following:
  • Recent UK proposals regarding withholding taxes on royalties have been largely overlooked but have wide ranging international implications. Malcolm Naylor, managing partner of Arthur Andersen’s UK tax and legal practice, explains
  • The New Zealand government has ironed out a number of kinks in the tax system. Changes have been made to the conduit tax rules and joint bank accounts, among other areas. Craig Elliffe and Nathan Banks of KPMG in Auckland look at the consequences for multinationals
  • The Thai government has responded to the economic crisis by removing tax obstacles to encourage mergers. Paul Stitt and Doug Allan of PricewaterhouseCoopers in Bangkok examine the relative merits of amalgamations and asset transfers under the new regime
  • The IRS’ active summer included final regulations on the treatment of distributions to foreign shareholders. This is good news for shareholders but taxpayers should beware the anti-abuse provisions. Mike Swanick and Aldrich Boss of PricewaterhouseCoopers in London report
  • The German government has lost a landmark case concerning the taxation of branches that will have an impact throughout the EU.
  • Britain has succeeded in temporarily blocking the EU's latest move towards tax harmonization.
  • The Japanese ministry of international trade and industry is to introduce tax reforms designed to encourage angel investment in Japan.
  • The Brazilian internal revenue has drafted a bill forcing the introduction of a minimum corporate income tax. A further bill reducing company tax exemption to one year is also under consideration in the senate.