Cyprus And India Tax Treaty Negotiations Finalised

On 29 June 2016 the negotiations for a double tax agreement between Cyprus and India were successfully concluded in New Delhi, for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion pertaining to taxes on income between the two countries, as confirmed by the Finance Ministry, with Cyprus accepting the proposed changes regarding capital gains and taxation, as set by the Indian government and the agreement is expected to be signed over […]

By |September 12th, 2016|

Brisal Decision: The CJEU Rules That Withholding Taxes May Be Contrary To EU Law

The Court of Justice of the European Union (CJEU) delivered its judgment in the Brisal1 case in July which could result in a fundamental change to the manner in which withholding taxes are applied on payments between EU member states and reduce the effective tax which may be suffered on certain cross-border payments.

The ruling may result in a lower withholding tax (WHT) burden for certain EU resident financial institutions, as well as the potential […]

By |September 9th, 2016|

IRS Advice Confirms Taxpayers Have Broad Discretion In Grouping Decisions

The IRS ruled in a recent technical advice memorandum (TAM 201634022) that a doctor could treat his medical practice and ownership interest in an outpatient surgery center as separate activities for the passive activity rules under Section 469. The IRS analysis confirms that the grouping rules allow taxpayers significant flexibility in their decisions and that the IRS hurdle for reversing them is high.

Section 469 generally prevents taxpayers from deducting losses from passive activities against […]

By |September 7th, 2016|