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Tax treaty briefing for August 2015

Speed read

Tax payable on the profits of an LLC may be available as a credit against UK tax payable. Domestic law and the relevant treaty will determine whether source country tax suffered on manufactured dividends is available as a tax credit. A client’s premises may constitute a taxable permanent establishment but the specific circumstances require review following Canada’s Dudney decision. Payments for software require careful examination in relation to withholding taxes, particularly in India.

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