Tags » International Tax

Permanent Establishment Risk

When one draft, review or negotiate for an international trade contract, as or for seller (or exporter), it is essential to have fundamental knowledge on local taxation, to minimize the risk of ‘permanent establishment’ (PE). 261 more words

Contract Law

Place of Effective Management: striking the right balance

International taxing principles

There are two main principles under which countries calculate tax on income — source and residency. Income derived by a person is likely to be taxed by a country because of a connection between the country and the generation of the income (source jurisdiction). 1,087 more words

Tax And Regulatory Services

His Kingdom For A Hearse

With England burying one of its monarchs today, 530 years late, I thought it appropriate to re-post this item from March 25,  2012.

Greatest Britain… 842 more words

International Tax

Greecing the wrong palms

Sneak, snitch, grass – those one syllable words do not convey an aura of approval. In school, where we imbibe the morality that plagues us for the rest of our lives, a telltale can expect a bigger punishment than the class-mate he is squealing on. 517 more words

International Tax

MAT not applicable to Foreign Companies

Came across a very interesting ruling of the ITAT (Delhi) in the case of Bank of Tokyo Mitsubishi UFJ Ltd. Vs. ADIT.

The ITAT relied on clause 49 of the Finance Bill 2002 and held that MAT was not applicable to foreign companies – something that the taxpayers have been shouting hoarse for the past several years. 10 more words


The Tax Treaty Briefing – March 2015

Allan Cinnamon is the trainer for the Quorum training courses on International Tax Planning Part 1 and Part 2. He regularly has articles published in Tax Journal. 165 more words


A drop of golden sun

From Wolfgang Amadeus Mozart to Adolf Hitler to Conchita Wurst, little Austria has always punched above its weight. It is ironic that the country that gave the world half its great classical music and, so far, all its World Wars, should be almost exclusively associated today with one kitch movie.Fifty years ago this week, a British actress appeared over a grassy horizon and, after the umpteenth  take, belted out ‘The Sound of Music’. 547 more words

International Tax