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withholding tax on intra-entity service payments

Branches, Head Offices, and Withholding Tax: Treating One Legal Person as Many for Tax Purposes

In company law, a branch and its head office are the same legal person. There is no separate share capital, no separate legal personality, no “other company” at the other end of the transaction. Yet, in the recent Bank of Nova Scotia v Comptroller of Inland Revenue (Saint Lucia) decision, the Caribbean Court of Justice...

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