In addition, the foreign party must fulfil the following beneficial ownership test, if required under the relevant tax treaty when generating income in the form of dividends, interest, or royalties: 1. The entity is not acting as an agent, nominee, or conduit; 2. The entity has controlling ...
Coe et al. (2004) argue that “value can take the form of technological rents by way of access to particular product or process technologies”. There are indeed risks and potential sanctions of such practices, notably the suspension or cancellation of their certificates. Many large firms ...
In addition, the foreign party must fulfil the following beneficial ownership test, if required under the relevant tax treaty when generating income in the form of dividends, interest, or royalties: 1. The entity is not acting as an agent, nominee, or conduit; 2. The entity has controlling ...
In addition, the foreign party must fulfil the following beneficial ownership test, if required under the relevant tax treaty when generating income in the form of dividends, interest, or royalties: 1. The entity is not acting as an agent, nominee, or conduit; 2. The entity has controlling ...