ITR Search | International Tax Review

Chile: Applicability of the beneficial owner concept for dividends in Chile

Germán Campos Kennett Fuenzalida Del Favero Double tax treaties (DTT) that follow the OECD's Model Tax Convention normally include the concept of 'beneficial owner' to determine the true owner of dividends, interests and royalties in order to apply special tax rates provided under such treaties.

December 15 2015

Canada: Canadian Federal Court pulls the reins in (slightly) on foreign information requests

Jean Marc Gagnon Alexandra Carbone In Amdocs Canadian Managed Services Inc. (ACMS), the Federal Court denied the Canada Revenue Agency's (CRA) request under section 231.7 of the Income Tax Act, Canada (Act) to compel ACMS to provide the CRA with documents and information requested in the course of a transfer pricing audit.

December 15 2015

Argentina: Argentina and Mexico sign double tax treaty

Andrés Edelstein Ignacio Rodríguez Argentina and Mexico signed a new double tax treaty (DTT) on November 4 in Mexico City. The subsequent exchange of ratification instruments is expected to occur soon and will make the DTT effective as from January 1 following such ratification process.

December 15 2015

Italy: Companies migrating to Italy: New ‘internationalisation’ decree introduces rules to determine assets and liabilities’ tax basis

Giuliano Foglia Marco Emma The 'internationalisation' decree (formally, legislative decree No 147 of September 14 2015) has been recently published on the Official Gazette and is now effective.

December 15 2015

Malta: Malta concludes treaty with Curaçao

Donald Vella Mark Galea Salomone On November 18 2015, Malta and the Netherlands concluded a treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income in respect of Curaçao.

December 15 2015

Intercompany charges below EBIT: A double-edged sword

Luis Abrantes, tax director and head of transfer pricing at Carlsberg Group, draws on practical experiences to unpick the intricacies of intercompany charges.

December 15 2015

Serbia: Treaty analysis: Serbia and Norway double taxation agreement

Ivana Blagojevic On September 4 2015, the Serbian Government approved the draft Treaty for Avoidance of Double Taxation, signed between Serbia and Norway on June 17 2015. The treaty's entry into force is pending ratification from both parties.

December 15 2015

Middle East: New incentives for foreign corporations in Kuwait

Kuwait has implemented new initiatives to help it compete for foreign investment, and further reforms could well be on the way.

December 15 2015

Ukraine: Ukraine amends list of low-tax jurisdictions

Nadiya Omelchuk On October 16 2015, the Cabinet of Ministers of Ukraine adopted Resolution No. 977-R, which amends the list of low-tax jurisdictions for transfer pricing purposes.

December 15 2015

Tax Relief

Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.

December 15 2015

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