Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.
This article provides a quarterly review of tax treaty developments.
Residence
Liechtenstein’s treaties with Andorra Switzerland and United Arab Emirates classify a Liechtenstein foundation as a company resident in Liechtenstein where specific conditions are fulfilled.
The Belgium/Japan protocol provides that a person is ‘liable to tax’ in a contracting state even where the tax laws of that contracting state provide that all or part of its income is exempted from tax or that such person is only subjected to tax with respect to some types of income.
The protocol to the Hungary/Oman treaty specifies that the place of effective management is where the day to day management activity is carried out by the senior officers including the executing officer.
Fiscally transparent entities
The Andorra/Liechtenstein Azerbaijan/Sweden Belgium/Japan ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.
This article provides a quarterly review of tax treaty developments.
Residence
Liechtenstein’s treaties with Andorra Switzerland and United Arab Emirates classify a Liechtenstein foundation as a company resident in Liechtenstein where specific conditions are fulfilled.
The Belgium/Japan protocol provides that a person is ‘liable to tax’ in a contracting state even where the tax laws of that contracting state provide that all or part of its income is exempted from tax or that such person is only subjected to tax with respect to some types of income.
The protocol to the Hungary/Oman treaty specifies that the place of effective management is where the day to day management activity is carried out by the senior officers including the executing officer.
Fiscally transparent entities
The Andorra/Liechtenstein Azerbaijan/Sweden Belgium/Japan ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
