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Pillar Two: Global minimum taxation
assets.kpmg— A Subject to Tax Rule (STTR), which overrides treaty benefits for certain related-party payments (including interest and royalties) that are not subject to a 9% minimum rate of tax in the recipient jurisdiction. The STTR will be creditable as a covered tax under the IIR and UTPR, i.e., the STTR applies first.
TAX CONVENTION WITH THE NETHERLANDS ... - IRS tax forms
www.irs.govJan 01, 1994 · The Convention also provides for the elimination of another abuse relating to the granting of U.S. treaty benefits to third-country permanent establishments of Netherlands corporations that are exempt from tax in the Netherlands. Under the new Convention, if the Netherlands has not dealt satisfactorily