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Tax Treaties
Canada
Fasken
On February 12, 2020, in Canada v Alta Energy Luxembourg S.A.R.L. (2020 FCA 43), the Federal Court of Appeal ("FCA") unanimously held that the general anti-avoidance rule ...
Miller Thomson LLP
Subsection 107(2) of the Income Tax Act[1] generally provides for a tax-deferred rollout of capital property held by the trustees of a Canadian-resident personal trust to their capital beneficiaries in satisfaction of their capital interests in the trust.
Rotfleisch & Samulovitch P.C.
Section 261 of Income Tax Act generally requires amounts reported on Canadian tax returns and other tax filings be reported in Canadian currency.
Bennett Jones LLP
The FCA found that the object, spirit and purpose of the relevant Can-Lux Treaty provisions is reflected in the clear and simple text of the Treaty.
Cyprus
A. Danos & Associates LLC
Cyprus and India signed on the 18th of November 2016 the revised double tax treaty between the two countries and a protocol that will allow India to tax capital gains in India.
Elias Neocleous & Co LLC
On 17 January 2020 the Cyprus-Kazakhstan double tax treaty (the agreement) entered into force.
C.Savva & Associates Ltd
In 2013, G20 and the Organisation for Economic Co-operation and Development launched the Base Erosion and Profit Shifting Project, a global initiative aimed at preventing tax avoidance.
European Union
Cadwalader, Wickersham & Taft LLP
The United Kingdom left the EU on 31 January 2020.
Gibraltar
ISOLAS
The main purpose of the Treaty is to eliminate double taxation between residents in Gibraltar and/or the United Kingdom in respect to taxes of income and gains.
India
Shardul Amarchand Mangaldas & Co
In light of the aforementioned, the AAR analyzed the purported role of the Mauritian company i.e. Bidvest in the joint venture.
SKP Business Consulting LLP
Direct Tax, 'Vivad se Vishwas' Bill, 2020 (scheme), which was introduced in Lok Sabha on 5 February 2020 faced various concerns from stakeholders on the limitations of the scheme.
Khaitan & Co
Further, Mauritius exempts taxation of capital gains under its domestic tax law.
Trilegal
The taxation regime witnessed some significant developments in 2019.
SKP Business Consulting LLP
Finance Minister in Budget 2020 has made some major changes to tax residency laws in India. The tax residency of a person was determined based on his/her stay in India (number of days).
Khaitan & Co
For the years in question, the Taxpayer did not file tax returns in India.
Kazakhstan
GRATA International
On February 6, 2020, the Parliament of Kazakhstan ratified the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting ("MLI").
Netherlands
Dentons
On February 19, 2020, the OECD published a draft policy document called "Model rules for Reporting for Platform Operators with respect to Sellers in the Sharing and Gig...
South Africa
Tabacks
This Tax Update covers the Commencement of Expat Tax, Final Carbon Offset Regulations, BGR: Relief in respect of Tax Treaties and Clarification on interpretation of "Group of Companies".
United States
Vistra
Tax treaties are a critical part of the global economy.
A. Danos & Associates LLC
Cyprus and Ukraine concluded a Protocol which amends the current double tax treaty between the two countries.
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