Latest updates for Tax Treaties

Fresh curated links around Tax Treaties are collected here so marketers can spot useful updates and turn timely ideas into posts faster.

Recent items include:

  • India strengthens DTAA with Sri Lanka to plug anti avoidance loopholes
  • Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings
  • The Exclusivity of Special Treaty Provisions for Pooled Investments: Analyzing the Court of Federal Claims Decision in S

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businesstoday.in /1 month ago

India strengthens DTAA with Sri Lanka to plug anti avoidance loopholes

Introduces concept of Principal Purpose Test, treaty not to be used to grant benefit for double non taxation and treaty shopping

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currentfederaltaxdevelopments.com /1 week ago

Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings...

Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...

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currentfederaltaxdevelopments.com /1 week ago

The Exclusivity of Special Treaty Provisions for Pooled Investments: Analyzing the Court of Federal Claims Decision in S...

The South Saskatchewan Community Foundation Inc. v. United States, No. 24-1391T (Fed. Cl. Aug. 25, 2026) For tax professionals advising cross-border tax-exempt organizations,...

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natlawreview.com /1 month ago

UK Withholding Tax on Interest- Simplification or Risk Shift?

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

You can list them on a single FFI (I know this cos it’s what I did and got NT codes for each)

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taxfoundation.org /1 week ago

Testimony: Legislative Proposal to Adapt the Income Tax Code to the Digital Economy Repeats the Economic and Legal Mista...

The Belgian proposal departs significantly from sound tax policy principles and risks generating substantial economic distortions, legal uncertainty, and trade frictions while rais...

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taxprofblog.aals.org /4 days ago

IMF: Taxing Cross-Border Services

In early August, the UN considered the text of an early protocol on the taxation of cross-border services, with a focus on expanded source-based taxation. A group of IMF coauthors...

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

Probably very hard. Buried in the uk tax small print is the point that if you spent most days in the uk it mqy come to tax you, more relevant is the uk france tax treaty and the l...

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businesstoday.in /1 month ago

Declared Australian salary in Indian ITR by mistake? Delhi ITAT says it can't be taxed under DTAA

The Delhi Income Tax Appellate Tribunal (ITAT) has provided relief to a taxpayer who inadvertently declared his Australian salary in his Indian ITR. It held that the income falls o...

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premiumtimesng.com /1 month ago

Nigeria, Hong Kong sign double taxation treaty to boost trade, investment

The agreement is expected to eliminate double taxation on income earned in both jurisdictions, strengthen tax cooperation and encourage greater cross-border investment. The post Ni...

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taxfoundation.org /2 weeks ago

Diving into the Differences Between Tax Transparency Regimes

The new public country-by-country reporting regimes adopted by the EU and Australia, and changes from the Financial Accounting Standards Board for financial accounts, are meant to...

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

Thanks very much George. I wasn’t sure if an FFI would be required to cover UK bank interest (as opposed to pension income) but you’ve answered my question. HMRC knows at some leve...

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thetaxtalk.com /1 week ago

Updated Return or FAST-DS: Which Route Works Better for Undisclosed Foreign Income or Assets?

Updated Return or FAST-DS: Which Route Works Better for Undisclosed Foreign Income or Assets?   The 60% vs 70% comparison can be misleading – because the two levies operate on comp...

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

Timp: I also read that NT codes are not issued for State pension and I think that that is the case. That’s correct as the state pension is always paid gross

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survivefrance.com /1 week ago

Double taxation expert comptable

Thanks George1. Food for thought. I’m finding it quite interesting that immigration rules and tax rules don’t always say the same thing also.

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

Hi Arcalia The UK interest is declared and taxed in France. No problems there. But I was just wondering if I went over the UK personal allowance, would I pop up on HMRC’s radar and...

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businesstoday.in /1 month ago

CBDT enables foreign asset disclosure in AIS: What taxpayers need to know before filing ITR

The CBDT has enabled taxpayers to view certain foreign asset information in their AIS, giving them greater visibility into overseas financial data received under global information...

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currentfederaltaxdevelopments.com /3 weeks ago

Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations: Analysis of the CFC Exemption Elec...

Foreign Currency Gain or Loss of Controlled Foreign Corporations, REG-103844-26, 91 Fed. Reg. (proposed Aug. 14, 2026) On August 13, 2026, the Department of the Treasury and t...

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wealthprofessional.ca /1 month ago

Global tax reforms could ease burden for Canadians working abroad

Deloitte's 2026 Global Tax Policy Survey finds OECD Safe Harbour reforms and simplified cross-border rules may benefit internationally mobile Canadian professionals

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taxfoundation.org /1 month ago

A Competitive Corporate Tax Code is Key to Sustaining Strong Economic Growth

The 12-year history of Tax Foundation’s ITCI shows that tax policy is constantly in flux around the world and that tax policy design choices matter for economic growth.

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currentfederaltaxdevelopments.com /1 month ago

Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)

Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance, REG-115145-25, July 31, 2026 The Department of the Treasury...

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natlawreview.com /5 days ago

What Every Multinational Should Know About … Securing Refunds for Finally Liquidated Entries

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survivefrance.com /1 month ago

HMRC dual taxation form - problem with French tax office

So is that a reminder that a separate FFI form should be provided to HMRC signed by French Impôts for each source of income or interest?

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natlawreview.com /1 month ago

Treasury Designates Certain CRAT-Annuity Arrangements as Listed Transactions: What to Review Now

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wealthprofessional.ca

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natlawreview.com

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taxfoundation.org

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taxprofblog.aals.org

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thetaxtalk.com

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businesstoday.in

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