| New publication: Turkey/Italy/Spain tax treaties |
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Date: 15 February 2010 Title: Turkey/Italy and Turkey/Spain Prevention of Double Taxation Treaties and their Impact on Cross-border Transactions Publishers: Lexis Nexis Synopsis: The analysis addresses the issue of whether Articles 23/4 and 22/1/d of the Turkey/Italy and Turkey/Spain prevention of double taxation treaties offer a unique opportunity for cross-border financial structuring in relation to dividends, royalties and interest income. For the reasons set forth below this author believes that the deemed (notional) foreign tax credit available under the Spain/Turkey and Italy/Turkey tax treaties may offer additional benefits in relation to cross-border lending and investments in debt and equity issues, provided that local tax offices can be convinced to apply the international tax treaty provisions. Link: Tax Law Community Contributor: Ali Şanver Related Links Expertise |
