jueves, 21 de julio de 2016

US and Luxembourg announce retroactive change to triangular branch rules in treaty PI

The US and Luxembourg on June 22, 2016, agreed to amend a protocol to the existing income tax treaty that addresses the potential for double non-taxation for US-source income of a Luxembourg company attributable to its US branch. The amendment affects the ‘triangular branch rule’ for taxpayers using US branches taxed in neither the US nor Luxembourg.  Once ratified, the provision could have retroactive effect to three days after Luxembourg parliamentary action, the timing of which is uncertain, but could be as early as late June 2016.
Source & more info: PwC

No hay comentarios:

Publicar un comentario