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International tax ( 138 results )

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Rulings
FC: Korean Supreme Court holds Collective Investment Vehicles as both tax residents & beneficial owners

Jul 06, 2021
Rulings
FC: South African Court holds situs of employment in Employer's State, not where services rendered

Jul 02, 2021
Rulings
FC: Supreme Administrative Court of Sweden: Timing of taxation of pension in the Resident State is not dependent upon the timing of its taxability in the Source State

Jun 25, 2021
Rulings
FC: Federal Court of Appeal of Canada: Right to social security doesn’t prevent taxation of pension income in Resident State

Jun 25, 2021
Rulings
FC: Danish Tax Council: COVID-19 forced stay does not constitute PE; Refers to OECD Memorandum dt. Apr 3, 2020

Jun 21, 2021
Rulings
FC: South African High Court holds 'Secondary Tax on Companies' paying dividend is tax on company, not on shareholders

Jun 18, 2021
Rulings
FC: French Supreme Court holds taxation of capital gains in source state doesn't deprive resident state's right to tax

Jun 10, 2021
Rulings
FC: Tax Court of South Africa applies Double Dip Theory while interpreting most Favoured Nation Clause

Jun 04, 2021
Rulings
FC: Supreme Court of Netherlands applies Double Dip Theory while interpreting most Favoured Nation Clause

Jun 04, 2021
Rulings
FC: Denmark Eastern High Court Accepts Look Through Approach while Applying Beneficial Ownership Criteria

May 28, 2021
Rulings
FC: Danish Tax Council – 'Internal support work' by employee from 'home office’ in Denmark, not PE of UK Co.

Apr 28, 2021
Rulings
FC: Danish Tax Council: Holds employee’s marketing activity to be ‘preparatory and auxiliary’ in nature; Confirms no-PE in Denmark

Apr 20, 2021
Rulings
FC: Danish Tax Court – Absence of limitation in DTAA doesn't confer indefinite time for initiating MAP

Apr 14, 2021
Rulings
FC: Holds tie-breaker inapplicable; Confirms Dutch Co.'s Canadian residency, applies central management and control test

Mar 10, 2021
Rulings
FC: Federal Court of Australia : Holds CA guilty of promoting 'tax exploitation scheme' for facilitating unreasonable R&D claims

Jan 07, 2021
Rulings
FC: Danish Tax Council : Applies 'nationality test' to resolve dual residency under Denmark-Germany DTAA

Jan 01, 2021
Rulings
FC: Australian Federal Court: Allows transfer of amalgamating Dutch co.'s Australian tax liability applying 'universal succession' principle

Dec 28, 2020
Rulings
FC: Danish Tax Council : Fiscal transparency of revocable foreign trust rests on 'effective' and 'definitive' separability from founder's assets

Dec 24, 2020

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