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United States and Canada Sign Long-Awaited Tax Treaty ProtocolRocco V. FemiaMarc J. Gerson
For example, if the board of a company is located in another country than where the firm has a permanent establishment (such as a factory or sales outlet), the firm may be subject to tax in both countries depending on the tax treaty between the two countries. In the context of ...
The Supreme Court has handed down judgment in an appeal concerning the allocation of taxing rights between the UK and Canada. The case relates to income earned from the sale of oil found in the UK continental shelf in the North Sea. The appeal concerned the application of the UK/Canada doub...
This study proposes to analyze the phenomenon of tax treaty abuse and the use of tax treaties as tools to avoid or minimize the taxation by residents doing business in a foreign jurisdiction. This study analyses a particular strategy usi... LB Cruceru - McGill University (Canada). 被引量: ...
The Permanent Establishment Concept In Double Tax Agreements Between Developed And Developing Countries: Canada/South Africa As A Case In Point To this end, the Canada/South Africa tax treaty is compared and contrasted with these two models. The concept of permanent establishment is reviewed in .....
RBC – UK Supreme Court finds that an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. Treaty Email this Content A Canadian corporation (“Sulpetro”), which had rights to direct the exploitation of, and to receive...
Singapore: Singapore's Budget 2025 introduces tax measures including a capped 50% corporate income tax rebate and new tax incentives for the innovation and maritime sectors. United Arab Emirates: The UAE has introduced a domestic minimum top-up tax for multinational enterprises, effective from fiscal...
August 17 (backdated to February 12), regarding the process for requesting a bilateral agreement between the ITA and the tax authority of another country under a tax treaty. Israel has income-tax treaties with 61 countries, including the US, the UK, Australia, Canada, South Africa, and the...
reduced from the U.S. statutory 30 percent withholding tax rate down to zero percent. Here, because Country X has been identified as a country that has discriminatory taxes, the subject tax treaty would be inapplicable and the interest payments (as described) in the first ye...