22/08/2025
This week’s International Tax Bytes video podcast:
- EU and US announce trade framework agreement.
- 5 international tax cases: (1) 3 Sigma Global Fund (does the word, “shares”, in India / Mauritius treaty cover derivatives?) (India); (2) Sky High (MLI in respect of India / Ireland treaty does not operate in India because it has not been separately notified) (India); (3) Rwenzori (“30% of EBITDA” interest limitation: gross interest vs. net interest) (Uganda); (4) Scania (does CIDE apply to remittances from Brazil under agreements which do not involve technology transfer?) (Brazil); and (5) Maryland digital advertising tax case (digital advertising tax “pass-through” provision breaches First Amendment of US Constitution, which guarantees free speech) (US).
- Other developments concerning Bahrain, Australia, China, India, Malaysia, Taiwan, Vietnam, Germany, Poland, Romania, Slovakia, UK, South Africa, Brazil, Canada, Colombia, US, and OECD.
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