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Tax treaty briefing for April 2015

Speed read

While a dependent agent permanent establishment (PE) may exist abroad or in the UK, its functions may be limited and thus attract minimal or no taxable profits. Access to tax treaty benefits in the host jurisdiction invariably poses a challenge to foreign partnerships. Payments for software require careful examination in relation to withholding tax. Treaty non-discrimination articles are a potentially powerful tool to combating tax disallowances in a foreign jurisdiction.

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