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BCLP

A Capital Blow for Deducting Management Expenses

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The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

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On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

BakerHostetler

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

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In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more

Goodwin

Luxembourg Circular On Interest Limitation Rules

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On 8 January, 2021, the Luxembourg tax authorities published Circular L.I.R. 168bis/1 on interest limitation rules (the “Circular”). The Circular provides much needed clarity to the interest limitation rules which have...more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

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