Ireland/UK DTA, Certification of ‘Form IRL-Individual’ and ‘Form Ireland-Company’
Under the Ireland/UK Double Taxation Agreement (DTA), Irish resident individuals and companies may claim relief at source or repayment of tax from the HM Revenue and Customs (HMRC), in respect of UK tax on certain sources of income. The sources of
See MoreVenezuela: Primary sector income tax exemption published
Decree 2,287 that establishes an income tax exemption for income derived from agriculture, forestry, livestock, poultry, fisheries, aquaculture and fish farming activities was published in the Official Gazette and entered into force on 28th March
See MoreUK: Use and Impact of Venture Capital Schemes
On 3 February 2016 HMRC published a research study of the use and impact of the Enterprise Investment Scheme (EIS) and Venture Capital Trusts. The research examined the incentive effects on investors of the two schemes; the impact on the ability of
See MoreUK-Tajikistan DTA in effect
The double taxation agreement (DTA) signed by the UK and Tajikistan on 1 July 2014 entered into force on 16 March 2015 and became effective in Tajikistan in relation to taxes on income and capital, other than withholding tax, for tax years beginning
See MoreECJ Rules in Fiscale Eenheid case
On 9 December 2015 the European Court of Justice (ECJ) issued a decision in the case of Staatssecretaris van Financiën v. Fiscale Eenheid X N.V. Fiscale Eenheid X NV was the name of a fiscal unity in the Netherlands, one of the companies of which
See MoreIndia: A taxpayer is entitled to foreign tax credit against the MAT liability
Recently, the Bangalore Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of: DCIT v. Subex Technology Ltd. [ITA No.913 (B) /2013, the court held that, credit for tax paid in a foreign country would be available under Section 90
See MoreTurkey: Unilateral APA updated
The tax administration has announced that it has concluded preparations for conclusion of a unilateral Advance Pricing Agreement (APA) between the tax administration and a taxpayer. According to the 5th paragraph of article 13 of the transfer
See MoreCanada: Impact of FTOs in Brazil for Canadian companies
The tax authority for Brazil verifies how to manage foreign tax offsets (FTO) and how to apply income tax treaty provisions for cross-border payments for services fees and described that under the presumed profit method, companies that are taxed are
See MoreRomania: Announces tax reforms
Romania is introducing a tax exemption on reinvested profit as part of an emergency ordinance. The tax exemption is to apply from 1 July 2014 and is to continue until the end of 2015. This is intended to encourage more investment in new assets in an
See MoreUS : Persons holding PFIC stock through tax-exempt organizations or accounts will be exempt from Form 8621 filing requirements
In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment
See MoreClarification of Russian MoF on tax withheld not in accordance with the tax treaty
Russian Ministry of Finance has published a letter no. 03-03-06/4/44331 which was issued on 23 October, 2013. This explains if corporate withheld tax by a Bulgarian branch belongs to a Russian company may be benefited against the corporate tax
See MoreTax treaty between India and United Kingdom – Indian decision on taxability of fees for technical services
The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 31 May 2013 in the case of Veeda Clinical Research Private Limited (ITA 1406/Ahd/2009) that the provision of market awareness and development in-house training services to an
See MoreUnited Kingdom: UK High Court decision on portfolio dividend tax
UK High Court decision concerns the portfolio dividend tax (holdings of less than 10%) under the previous tax law which provided double tax relief for foreign withholding taxes paid on the dividends and no relief for any underlying tax. UK has moved
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