Date: 4 June 2010

Publishers: TerraLex

Synopsis:

The analysis below 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: TerraLex Newsletter (this article was also published by Lexis Nexis)

Contributor: Ali Şanver, Tax