June 2018
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International Correspondents
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Sponsored
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Sponsored by PwC ChileOver the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.
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Sponsored by Fenwick & WestThe 2017 Tax Act added new Section 864(c)(8) on the sale of a partnership interest. The provisions introduce rules that were disputed in Grecian Magnesite v Commissioner.
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Sponsored by Dhruva AdvisorsThe issue of whether a waiver of loans results in taxable income for the borrower has been a controversial one in India.