Brazil s Superior Court of Justice ruling on taxation of technical services internationaltaxreview.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from internationaltaxreview.com Daily Mail and Mail on Sunday newspapers.
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Since the Brexit axe fell many businesses both in Italy and in
the UK that formerly enjoyed a good cross-border trading
relationship have had to find an alternative route to their
previous markets.
For UK businesses wishing to conduct business in Italy, there
have been a number of reforms made with the view of streamlining
and simplifying the procedures required for foreign business to
start and operate a business in Italy. The opportunities are
open to EU Member States as well as non-EU countries. A
Russia hails Maltaâs reciprocal moves on double taxation
During the talks with Malta, mutual interest in cultivation relations in various spheres was also brought to light
SOCHI, May 25. /TASS/. Malta’s prompt ratification of the bilateral Double Taxation Convention will contribute to the legal regulation of ties with Russia in this area, Russian Foreign Minister Sergey Lavrov said on Tuesday at a joint press conference after talks with his Maltese counterpart Evarist Bartolo. We have noted Malta’s efforts to adapt national laws, specifically in the tax sphere, to the requirements of international financial regulators, Lavrov said. We commend our partners for the prompt ratification of the protocol of the bilateral convention on the avoidance of double taxation. This will definitely benefit the legal regulation of relations between our countries in this sphere, he specified.
IHTM04273 - Foreign settled property: the settlor s domicile
Foreign settled property is only excluded property (IHTM04251) where the settlor was domiciled (IHTM13000) outside the UK at the time when the property (IHTM04030) became comprised in the settlement. The domicile of the trustees (IHTM16050) and beneficiaries is not relevant. It follows that, as a general rule, property settled by a UK domiciliary is not excluded property and is therefore within the scope of Inheritance Tax regardless of the locality (IHTM27071) of the property. This is so even if any person entitled to a qualifying interest in possession (IIP) (IHTM16062) in the property, who is beneficially entitled (IHTM04031) to the property, IHTA84/S49 (1) and S49 (1A) is domiciled abroad.
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While much of the focus has remained on the efforts of the Organisation for Economic Cooperation and Development (OECD) with respect to digital taxation, the United Nations (UN) has finalized revisions to the UN Model Double Taxation Convention (UN Tax Treaty) that would specifically address the taxation of “automated digital services.” On April 20, 2021, the UN approved the final version of new Article 12B of the UN Tax Treaty, Income from Automated Digital Services. Generally, the approach taken by Article 12B is to permit a withholding tax on gross payments for “automated digital services” made by a resident of one treaty country to a resident of the other treaty country. In order to eliminate the withholding, the recipient can declare a permanent establishment in the payor jurisdiction and instead be subject to tax on its net income from automated digital services. This approach represents a departure from tr