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Quarterly tax treaty briefing: Spring 2016

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Based on a substantive and functional rather than legal approach the Spanish National Court has affirmed the lower court’s decision that Dell’s Spanish commissionaire constituted a PE of its Irish principal. Spanish courts have tended to follow this approach in contrast to other jurisdictions such as France Italy and Norway. The Delhi High Court has ruled that satellite transmission fees are a service rather than equipment rents subject to withholding tax. The Budget includes proposals to tax non-residents’ profits from dealing and developing UK land irrespective of a UK PE. The OECD has released a discussion draft on the residence of pension funds for treaty purposes. BEPS Actions 6 and 7 (treaty and PE abuse) continue to be reflected in new treaties. The new US Model Treaty also contains a number of provisions derived from Actions 6 and 7. Finance Bill 2016 will...

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