Could a transfer pricing adjustment for a domestic enterprise lead to 'dividend' characterization (under tax treaty) for the associated enterprise? (2/2)
April 14 2023
This is episode 7 in the special video discussion series on Art. 10 (Dividends) of tax treaties.
Other video discussions in the Art. 10 (Dividends) series:
Could an indirect shareholder be considered a shareholder for the purposes of a tax treaty?
Could notional interest be treated as disguised dividend?
Proceeds from share buyback: Capital gains (Art. 13) or dividends (Art. 10)?
Tax treaty definition of 'dividends': How to interpret the term 'jouissance rights'?
Important Disclaimer:
Efforts have been made to avoid errors or omissions in the content on this website. In spite of that, errors could creep in. Hence, you are advised to seek legal or professional advice where necessary. It is notified that, under any circumstances, neither the author nor any related person, entity, or service provider shall be responsible to anybody for any damage or loss.
Please also note that due to the nature of the subject-matter discussed on this website, the information contained within it and on any pages linked to/ from it may be subject to change, without notice.
