ITR Search | International Tax Review

Brazil: Computer software included in the concept of copyrights for the purposes of the double tax convention between Brazil and Finland

Michela Chin Ruben Gottberg The Brazilian Federal Revenue (RFB) has issued tax ruling COSIT n. 4/2016, allowing the application of a 10% withholding tax (WHT) rate on payments for the use of computer software as provided by the double tax treaty (DTT) between Brazil and Finland.

July 12 2016

Argentina: Tax amnesty and developments sent to Congress

Andrés Edelstein Ignacio Rodríguez After several unsuccessful attempts to launch a tax amnesty under the previous administration, the Executive Branch that took office last December has drafted and sent to the Congress a tax amnesty programme.

July 12 2016

Greece: Treaty analysis: Greece-Cyprus DTT tax credit mechanism relating to dividend payments

Kalliopi Kalogera Greece has a broad network of Double Tax Treaties (DTTs) in place, however, only a handful of them (e.g. Albania, Georgia, Uzbekistan) include clauses permitting the tax credit of the corporate tax paid on profits in the country of the distributing entity against the income tax to be paid for dividends in the country of residence of the receiving person (individual or legal entity), among which is the DTT between Greece and Cyprus.

July 12 2016

Canada: Important Deadline Approaching under Canada’s “upstream loan” Rules

Ian Caines August 19 2016 will be an important deadline under Canada's "upstream loan" rules for foreign affiliates. After that date, the rules will begin to apply to certain historical intra-group indebtedness that was previously exempt due to a limited period of transitional relief.

July 12 2016

Ireland: Guidance published on secondary reporting mechanism for CbC reporting

Joe Duffy Shane Hogan During June 2016, the Irish Revenue Commissioners (Irish Revenue) published guidance on the secondary reporting mechanism included in Ireland's legislation implementing the OECD's recommendations on country-by-country (CbC) reporting.

July 12 2016

Special features - July/August 2016

Read this month's special features on Financial services - Sweden, Financial services - Switzerland, BEPS, Foreign investment - New Zealand and Intangibles

July 12 2016

Serbia: Serbia clarifies registration of foreign entities for VAT purposes

Aleksandra Rafailovic On May 23, 2016, the Serbian Ministry of Finance announced its clarifying opinion on the tax representation of a non-resident entity for the purpose of implementing the Law on Value Added Tax and the obligation to register for VAT.

July 12 2016

Separating intangible value by surveys

In the ninth in a series of articles on intangibles and finance, Philip de Homont and Alexander Voegele of NERA Frankfurt show how to handle surveys for intangibles and transfer pricing.

July 12 2016

Tax Bill to have significant impact on financing transactions

As New Zealand proposes to revise its non-resident withholding tax rules and how they apply to interest, Shaun Connolly and Chris Harker of Russell McVeagh examine the implications for foreign and domestic parties to financing transactions.

July 12 2016

Editorial

I join as the new editor of International Tax Review at a very exciting time.

Anjana Haines, July 12 2016

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