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triangulation News

China Sets Out How To Determine Beneficial Owner For Treaties

by Mary Swire,, Hong Kong

Tuesday, February 13, 2018

On February 3, 2018, China's State Administration of Taxation set out new rules on the disallowance of tax treaty benefits where an entity fails to demonstrate it is the beneficial owner of Chinese assets from which passive income is derived. Read Full Story


Irish FinMin Considers Impact Of Brexit On Taxes

by Jason Gorringe,, London

Wednesday, August 2, 2017

As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland's tax system. Read Full Story


Working Group To Discuss India, Mauritius DTA

by Mary Swire,, Hong Kong

Monday, January 14, 2013

A joint working group is set to meet next month to discuss the double tax agreement between India and Mauritius, which, India has long complained, allows investors to avoid Indian taxes to an unacceptable degree. Read Full Story


OECD Clarifies Model DTA Interpretation

by Jason Gorringe,, London

Wednesday, October 24, 2012

The Organization for Economic Cooperation and Development has released for consultation two updated draft discussion papers to clarify the interpretation of 'beneficial ownership' and 'permanent establishment' used by tax authorities to assess in which nation, and at what rates, corporates should be liable to withholding taxes on prescribed passive income received from cross-border economic activity covered by an OECD model double tax agreement. Read Full Story


India To Tax More Merger Deals

by Lorys Charalambous,, Cyprus

Monday, June 4, 2012

The Indian government has a list of corporate merger deals from which it hopes to claw back billions of dollars in back taxes with a proposed retrospective amendment to income tax law. Read Full Story


India Reassures US On Retrospective Tax Plans

by Mike Godfrey,, Washington

Tuesday, April 24, 2012

India's Finance Minister Shri Pranab Mukherjee has defended plans for retrospective tax legislation, telling the US Secretary of the Treasury that the proposals merely clarify the intent of current laws. Read Full Story


Vodafone Challenges Indian Tax Law

by Mary Swire,, Hong Kong

Monday, April 23, 2012

The ongoing tax dispute between India and Vodafone has erupted again, with the telecoms company now serving a Notice of Dispute against the government's controversial new retrospective tax legislation. Read Full Story


OECD Forum To Simplify Transfer Pricing Rules

by Ulrika Lomas,, Brussels

Friday, March 30, 2012

Meeting at the first Organization for Economic Cooperation and Development Global Forum on Transfer Pricing, tax officials from 90 countries agreed on the need to simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution. Read Full Story


Vodafone Wins Indian Tax Dispute

by Mary Swire,, Hong Kong

Wednesday, January 25, 2012

India’s Supreme Court has ruled that Vodafone Group Plc is not liable for a USD2.2bn bill in back taxes and penalties after the USD11.2bn acquisition of Indian mobile phone company Hutchinson Essar in 2007. Read Full Story


Vodafone's Indian Tax Bill May Double

by Mary Swire,, Hong Kong

Wednesday, July 6, 2011

Leading telecoms company Vodafone has warned that the firm's back tax liability in India could double if the Indian Supreme Court rules in favour of the country's tax authorities with regard to a long-standing tax dispute. Read Full Story



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