concluding that, under the terms of the Double-Tax Treaty entered between Chile and Spain, Chile would not have taxing rights under circumstances in which a Spanish resident indirectly transferred a Chilean company. The appellate decision rejected criteria that the Tax Court had applied...
Intertax International Tax ReviewDevelopments in Spain in respect of substantial holdings are described in Aurora Ribes Ribes, `Taxation of Capital Gains in Spanish Tax Treaties: The Belgium-Spain Double Taxation Convention on Income and Capital' (2004) 32 Intertax 486. For developments in Italy, ...
In a decision published on 12 June 2023, the Supreme Court confirmed that the Spanish Tax Authorities (STA) cannot simply override a tax residence certificate issued by a foreign tax administration for the purposes of Double Tax Treaties (DTT) on the basis of Spanish domesti...
tax treaty interpretation and residence; (2) Permanent establishment (PE); (3) Business profits and transfer pricing; (4) Labour income; (5) Beneficial ownership, royalties and capital gains; (6) Relief for double taxation and limitat... MV Hulten,AG Jallai - 《Intertax》 被引量: 0发表...
Tax Implications – Comply with both US and Spanish tax regulations. The tax treaty between the two countries may offer relief from double taxation. Consult a tax advisor. Time Zones – Flexibility is required to manage the time difference, which might affect your working hours. ...
Maybe the Treaty of Lisbon wasn’t such a good idea after all. What happened next was a catastrophe that is only possible in a Central Banking/Tax Farm disconnect that the Eurozone’s half baked approach to unity has left as the norm. You see, fellow taxpayer, in the United States of ...
In particular, the author focuses on the new provision on the taxation of capital gains as a consequence of the alienation of shares in the Belgium-Spain double tax treaty.Ribes, ADevelopments in Spain in respect of substantial holdings are described in Aurora Ribes Ribes, `Taxation of Capital...
The article examines the position of the Spanish tax authorities, courts on the limited interpretation of treaty terms regarding the taxation of royalties. It discusses the article 3(2), 12(2)(a) of the Spain-United States Income Tax Treaty (1990). Contradicting points related to categorizing ...
New Developments of the Spanish-United States Tax TreatyBerkeley Electronic Press Selected WorksWilliam Byrnes
Clients' residency status; Double taxation treaty between Great Britain and Spain; Tax liability; Wealth and inheritance taxes.EBSCO_bspMoney Marketing