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Tax treaty briefing for March 2015

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The sourcing of royalties under domestic and treaty provisions will determine whether withholding tax applies to cross border payments into or out of the UK. Foreign jurisdiction requirements for a local holding company to head a consolidated tax return may be challenged through a treaty non-discrimination article. Hybrids, including partnerships, present challenges of treaty application. Recent anti-avoidance developments in China and Denmark reflect government concerns with treaty shopping, stimulated by the BEPS action 6 report on treaty abuse.

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