US: IRS extends treaty benefits to reverse foreign hybrids subject to branch profits tax
The IRS Chief Counsel ruled that reverse foreign hybrids may qualify for reduced branch profits tax on dividend equivalent amounts attributable to treaty-eligible owners. The US Internal Revenue Service (IRS) Chief Counsel has determined that
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Philippines streamlines tax treaty rules for government securities
The Philippines Bureau of the Treasury (BTr) announced in a press release on 5 November 2024 the implementation of a streamlined tax treaty procedure for non-resident investors in Government Securities (GS). This initiative is part of the
See MoreFrance: Supreme Court decides on the definition of residents for tax treaty purposes
On 2 February 2022, the French Administrative Supreme Court ruled that a company benefiting from a temporary and partial corporate income tax exemption should be considered liable to tax and therefore a tax treaty resident. The French tax
See MoreUK: LOB Clause of US-UK treaty does not restrict unilateral foreign tax credit
Aozora GMAC Investments Limited, resident in the UK, was a subsidiary of a Japanese bank. The taxpayer made a loan to its subsidiaries in the US. Article 11(1) of the US-UK double tax treaty provided for exclusive taxation of the interest income
See MoreTaiwan announces the amendments to the tax treaty rules and PE rules
On 12 August 2021, Taiwan’s Ministry of Finance has announced the amendments to the “Regulations Governing Application of Agreements for the Avoidance of Double Taxation with Respect to Taxes on Income”. The amended regulations have come into
See MoreBulgaria: Government imposes penalty for late application of tax treaty relief
On 18 November 2020, parliament passed amendments to the Tax and Social Security Procedure Code at first reading, which aims to ensure the payment of withholding tax on cross-border payments and the effectiveness of tax control in the event of
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