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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Introduces concept of Principal Purpose Test, treaty not to be used to grant benefit for double non taxation and treaty shopping
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...
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,...
You can list them on a single FFI (I know this cos it’s what I did and got NT codes for each)
The Belgian proposal departs significantly from sound tax policy principles and risks generating substantial economic distortions, legal uncertainty, and trade frictions while rais...
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...
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...
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...
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...
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...
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...
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...
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
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.
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...
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...
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...
Deloitte's 2026 Global Tax Policy Survey finds OECD Safe Harbour reforms and simplified cross-border rules may benefit internationally mobile Canadian professionals
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.
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...
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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