Tax treaties

Tax treaties (often referred to as double tax treaty, DTT or double tax agreement, DTA) were initially introduced to regularize cross border taxation of internationals investments and activities to avoid double taxation of the same income in various concerned jurisdictions. The target was to set the rules how and where cross border activities were to be taxed and to ensure tax benefits for the investors abroad. Double tax treaties are highly efficient and have been in use since decades. However, DDT application is becoming more complex in the recent years. Economic substance of the corporate structure involved, and the economic essence of the taxable transaction are considerable issues and are closely looked into by the involved tax authorities. Anti-abuse rules and tests applied by jurisdictions differ from country to country, but the approach is commonly strict and will become even stricter in the coming years. 

MP Part assists our clients in evaluating the applicability of the double taxation agreements to personal investment activities as well as to international business and holding structures. We will look into the substance of the transaction to identify the risks of economic double taxation and the ways to limit or eliminate such risks. Our services include:

  • analysis of the applicability of the international agreements in the field of taxation;
  • risks analysis, planning and supervision of implementation of the treaty provisions;
  • documentation of the cross-border transactions, administration of tax refunds and/or applying tax credits to ensure utilization of treaty benefits.