The 2014 Update, as adopted by the OECD Council on 15 July 2014, includes changes that were previously released for comments, including the meaning of “beneficial owner”. Numerous additions and deletions to Commentaries on various Articles, including positions of non-member countries, are also included.
Nathan Boidman of Davies Ward Phillips & Vineberg highlights how the recently enacted double tax agreement between Canada and Hong Kong affects multinationals and individuals investing in both countries.
Rafaela Brito and Fernando Moreira provide an overview of the carbon emissions trading market in Brazil.
After several years delay, the reform, theoretically as a result of incorporating the GAFI’s recommendations into Spanish legislation on the Prevention of Money Laundering and the Financing of Terrorism, the Royal Decree enacting the Regulation governing the implementation of Act 10/2010 of 28 April on the Prevention of Money Laundering and the Financing of Terrorism was published in the Official State Gazette of 6 May 2014.
Clients often ask about the application of US tax treaties to reduce or even eliminate taxation at source on US source income paid to non-US persons. Here is an overview of how the limitation of benefit applies when considering US tax treaties, using Ireland as an example.
The purpose of this article is to review double tax treaties with a view to gaining an understanding of what they are, how they operate, how they are interpreted and concentrate on the rationale behind them.