Allan Cinnamon reviews the latest tax treaty developments, including UK companies seeking group relief for losses of foreign subsidiaries; potential exposure to Indian tax on consultancy fees and exemptions in operating aircraft; and Maltese companies enjoying special tax treatment potentially being denied treaty benefits.
between the Mauritian Revenue Authority and the South African Revenue Service signed on 22 May 2015 has established the factors to be considered in determining the dual residence of companies. In line with BEPS Action 6 art 4.3 of the Mauritius/South Africa treaty provides for a mutual agreement procedure (MAP) tiebreaker rather than the traditional effective management test. The determining factors detailed in the MOU are in line with amendments to para 24...
