Archive: capital tax

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Argentinia and Chile: Tax Court decision on treaty – inapplicable based on application of GAAR

Argentinia and Chile: Tax Court decision on treaty – inapplicable based on application of GAAR

September 26, 2013. Tags: , , , , , ,

On 14 August 2013, the Argentine Federal Tax Court gave its decision in Molinos Rio de la Plata S.A., specifically, on whether dividends paid by …

New Luxembourg-Saudi Arabia tax treaty published [TAX ALERT]

New Luxembourg-Saudi Arabia tax treaty published [TAX ALERT]

September 25, 2013. Tags: , , , ,

The text of the income and capital tax treaty with Saudi Arabia was published recently. The treaty was signed on 7 May 2013. Before coming into …

Austria: Ministry of Finance publishes Express Answer Service information on PE definition

Austria: Ministry of Finance publishes Express Answer Service information on PE definition

September 24, 2013. Tags: , , , , ,

The Ministry of Finance recently published information issued in connection with the Express Answer Service, dated 5 August 2013, relating to the definition of permanent …

Luxembourg and Russia: Russian Ministry of Finance clarified tax treatment of interest paid to a Luxembourg resident according to treaty

Luxembourg and Russia: Russian Ministry of Finance clarified tax treatment of interest paid to a Luxembourg resident according to treaty

August 15, 2013. Tags: , , ,

On 11 July 2013, the Ministry of Finance issued Letter No. 03-08-05/26970 clarifying the tax treatment applicable to interest paid to a non-related Luxembourg resident …

Treaty between Russia and Cyprus – Russian MoF clarifies tax obligations in case of income derived from letting immovable property

Treaty between Russia and Cyprus – Russian MoF clarifies tax obligations in case of income derived from letting immovable property

August 6, 2013. Tags: , , ,

On 9 July 2013, the Russian Ministry of Finance issued Letter No. 03-08-05/26489 clarifying the tax obligations if a company resident in Cyprus derives income …

Norway proposes changes to the Limited Companies Act [TAX ALERT]

Norway proposes changes to the Limited Companies Act [TAX ALERT]

July 8, 2013. Tags: , ,

On 5 April 2013, the Norwegian government proposed significant changes to the Norwegian Limited Companies Act. The Parliament is expected to consider the proposal in the …

Treaty between Russia and US – Russian MoF clarifies application of tax treaty to a sole proprietorship

Treaty between Russia and US – Russian MoF clarifies application of tax treaty to a sole proprietorship

May 2, 2013. Tags: , , , , , ,

Recently, the Ministry of Finance issued Letter No. N 03-08-05/9437 to clarify the withholding tax rate applicable to dividends distributed by a Russian entity to …

Argentina-Russia tax treaty enters into force [TAX ALERT]

Argentina-Russia tax treaty enters into force [TAX ALERT]

November 1, 2012. Tags: , , , ,

On 15 October 2012 the Government of the Russian Federation notified the Argentine government of the fulfillment of its domestic requirements for the entry into …

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