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Israel's Supreme Court upholds tax treaties in foreign levy case

The Supreme Court analyzed the situation and the law in detail. In the end the Court ruled against the employing companies for a number of reasons.

Australia , United-kingdom , Israel , Moldova , China , South-africa , Canada , Romania , Israeli , Israelis , Economic-recovery-law-program

Why Permanent Establishments have no guidance and mechanism in Guatemala?

Permanent Establishments (hereinafter "PE") are regulated in Article 7, of Decree No. 10-2012 of the Congress. Although its regulation dates to 2013…

Guatemala , Guatemalans , Organization-for-economic , Model-convention , Tax-administration-office , United-nations-organization , Permanent-establishments , Source-states , Economic-co-operation , Law , Awyers

Spotlight: taxation of executives in Hungary

A general introduction to the tax regime applicable to executives in Hungary, including key tax planning considerations.

Hungary , Hungarian , Model-convention , Member-state-of-the-european-union , Personal-income-tax , Double-taxation , Hungary-stock , Social-security , Member-state , European-union , Social-security-regulation

Sale of real estate shares by non-Mexican residents

Santiago Llano and Eric Palacios of Ritch Mueller explain why non-Mexican residents should analyse whether Mexican source income exists when transferring participation in a non-Mexican resident entity that owns directly or indirectly immovable property in Mexico.

Mexico , Mexican , Model-convention , Model-tax-convention-on-income , Capital-of-the-organisation-for-economic-cooperation , Mexican-income-tax-law , Mexican-financial-reporting-standards , Model-tax-convention , Economic-cooperation , Mexican-financial-reporting ,

The new Luxembourg-UK double tax treaty: key points for investors in UK real estate

On 7 June 2022, the United-Kingdom (UK) and Luxembourg signed the text of the new double tax treaty. The date on which the treaty will enter into…

United-kingdom , Luxembourg , Model-convention , European-union , Luxembourg-united-kingdom , Specialized-investment-funds , Reserve-alternative-investment-funds , Parent-subsidiary-directive , Law , Awyers , Egal

A general introduction to transfer pricing in Netherlands

This article provides a general overview of the law and practice surrounding transfer pricing in Netherlands, including broader taxation issues and the outlook for future developments.

Paris , France-general- , France , Netherlands , Dutch , Van-kalmthout , Eu-arbitrage-convention-the , Model-convention , European-commission , Model-tax-convention , Starbucks , Supreme-court

A general introduction to transfer pricing in United Kingdom

This article provides a general overview of the law and practice surrounding transfer pricing in United Kingdom, including broader taxation issues and the outlook for future developments.

United-kingdom , Model-tax-convention-the , Organisation-for-economic , Model-convention , Taxation-international , Her-majesty , Economic-co-operation , Model-tax-convention , Pricing-guidelines , Upper-tribunal , Chargeable-gains-act

A general introduction to transfer pricing in Cyprus

This article provides a general overview of the law and practice surrounding transfer pricing in Cyprus, including broader taxation issues and the outlook for future developments.

Cyprus , Tax-department , Organisation-for-economic , Model-convention , Eu-arbitration-convention , Model-tax-convention , Economic-co-operation , Transfer-pricing , Final-reports , Transfer-pricing-guidelines , Pricing-guidelines

How to use hidden tools for managing international tax disputes

Taxpayers should not overlook the hidden tools in the MAP toolbox when it comes to dispute resolution, particularly supplementary dispute resolution (SDR). Here Emile Simpson and Peter Nias write about the routes open to businesses.

United-kingdom , Centre-for-effective-dispute-resolution , Capital-the-convention , Model-convention , Model-double-taxation-convention-on-income , Double-taxation-convention , Effective-mutual-agreement-procedures , Contracting-state , Contracting-states , Effective-dispute-resolution ,

Italian Revenue Agency Expressed Itself Once Again On The "Arm's Length Principle" .

Italian Revenue Agency Expressed Itself Once Again On The "Arm's Length Principle" . Legal News and Analysis - Europe - Dispute Resolution, Tax -

Italy , Italian , Tax-administration , Model-convention , Italian-revenue-agency , Tax-office , Italian-tax-code , Double-tax-treaties , Transfer-pricing ,