Category: Legislation

Canada Revenue Agency / Capital gains / Capital Gains Tax / Double Tax Treaty / Income Tax Act / Legislation / Tax Avoidance / Tax Laws / Tax Planning

Canada: “Changing Of The GAAR”: A Background On The General Anti-Avoidance Rule, And Canada’s Attempt To Expand Its Tax Power In The 2022 Budget

Published by: Mondaq - April 29, 2022

The Budget purports to introduce several new financial and taxation regimes, as well as enhance several existing mechanisms. One of the existing taxation mechanisms proposed to be amended is the General Anti-Avoidance Rule (the "GAAR"). The Government initially indicated they would be amending the GAAR in the 2021 Budget. The 2022 Budget now provides some additional detail, though we are still waiting for the actual legislation. ... - Continue reading

Business / Corporate Tax / Intragroup Services / Legislation / OECD / Tax Deductibility / Tax Planning / Transfer pricing

Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract

Published by: MNE Tax - March 9, 2022

In recent years, the Spanish tax administration and Spanish courts have had a clear tendency to challenge the provision of intragroup services, denying its corporate income tax deductibility and increasing the tax burden for taxpayers carrying out these transactions in Spain. ... - Continue reading

Arbitration / Arbitration Act / Bermuda / Debt / Immovable Property / Infrastructure / Interest / Legislation / Offshore / Offshore Trusts

Bermuda: Enforcement Of Judgments 2020 – Trends And Developments

Published by: Mondaq - September 1, 2020

Bermuda is a self-governing overseas territory of the United Kingdom. It has a population of over 60,000 people on a land mass of just 21 square miles. The island group is located in the Atlantic Ocean, approximately 760 miles due east of Cape Hatteras, North Carolina. Surrounded by coral reefs and the Gulf Stream, Bermuda remains a popular destination for tourists but its infrastructure, flexible and innovative corporate structures and strong regulatory environment have made it a leading offshore jurisdiction for company incorporations, including for a number of companies listed on the main New York and Hong Kong stock exchanges ... - Continue reading

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