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OECD has work to do on APA guidelines
Caroline Silberztein, head of the transfer pricing unit in the OECD centre for tax policy and administration answers Catherine Snowdon's questions about the problems that face APA programmes today and how the OECD will work to improve its guidelines in this area. September 2010
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Clinging to the changing face of APAs
Since APAs became an option for corporate taxpayers, there has been a gradual shift in their purpose and a split in taxpayer and government approaches to the agreements. Catherine Snowdon discovers how the process of getting an APA needs to develop to better suit modern business. September 2010
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Congress blows whistle on economic substance
When the US Congress codified the long-standing common law doctrine known as economic substance, many tax practitioners were not shy about criticising the move, expressing concern about the effects of this new law on corporate tax planning. Erin Kelechava spoke to tax lawyers, professors, and policy experts and found out that a statute that was meant to clarify what an abusive transaction is may end up achieving the opposite result. July / August 2010
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Claim payments not subject to premium tax
Alexander Skowronek and Nathalie Grenewitz of Luther-Taxand in Germany discuss the effect a landmark decision in a car insurance tax case will have on the wider insurance industry. Including diminishing the risk that the deductible borne by the policyholder will be subject to German premium tax. September 2010
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Group guarantees remain a tax minefield
Megan Lapwood and Mark Atkinson of Deloitte in Switzerland describe how cross guarantees and the overall flow of benefits derived within a multinational group from external funding may affect how guarantee fees should be charged. September 2010
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VAT travel service margin scheme concerns all taxpayers
The value added tax travel service margin scheme involves complex issues that concern businesses of all types, Stephen Dale of Landwell & Associés investigates the progress being made and how Europe might better develop the legal framework in this area. September 2010
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Taxpayers must look at marketing intangibles again
The Delhi High Court ruling in the Maruti Suzuki case has confounded the opinion of companies with subsidiaries conducting marketing in India. Srinivasa Rao and Rajendra Nayak of Ernst and Young in India analyse the implications. September 2010
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Ireland imposes mandatory disclosure obligations
Ireland has introduced a mandatory disclosure regime under the Finance Act 2010. Cliona Donnelly of William Fry – Taxand explains how the introduction of this new regime sets a new landscape for tax advisers and taxpayers alike. September 2010
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Draft tax code brings many international changes
Sergiy Melnyk of Salans in Ukraine describes how the new draft tax code in Ukraine constitutes a significant departure from previous international tax provisions in the country. September 2010
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Coming to terms with Schedule UTP
Taxpayers responded to the IRS' announcement about the reporting of uncertain tax positions with consternation. Erin Kelechava finds out that most corporate taxpayers regard Schedule UTP as a major departure from the relationship that has developed over decades between taxpayers and the IRS. September 2010
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Generally arduous and risky
The UK tax market's reaction to the idea of a General Anti-Avoidance Rule (GAAR) has been generally unsupportive. Sophie Ashley investigates how other countries' experiences with a statutory anti-avoidance rule might influence the government's decision on whether to introduce such a rule. September 2010
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Private equity beware
Stephen Rogers of Nexia International member firm, Nexia Court & Company in Sydney, explains what private equity companies need to look out for in Australia. September 2010
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Rising VAT rates here to stay
Several countries have announced or implemented VAT rises in the last few months. Salman Shaheen looks at the growing trend towards higher VAT around the world and why the global recession means it looks set to continue. September 2010
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Asia tax directors speak out against extra pressure
Tax executives are being placed under extra pressure. Their busy times are no longer just at year end, they are all year round. This is where external advisers step in to reduce the workload. Jack Grocott analyses the results of the Asia-Pacific Client Services Poll 2010 and investigates the problems executives are facing and how advisers can help. September 2010
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Indirect taxes are on the up and up
Increased emphasis on indirect tax is forcing taxpayers to start placing extra focus on effective strategies to generate more cash from this area of their business. At June's Indirect Tax Forum speakers outlined how indirect tax should become the top priority for businesses across the world. July / August 2010
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South Africa joins competition for holding companies
Its position as Africa's leading economy will make South Africa's proposed headquarter company regime appealing to foreign investors, believes Peter Dachs of Edward Nathan Sonnenbergs July / August 2010
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What effective tax rate lacks as a performance indicator
The effective tax rate is flawed as a measure of the value created by a company's tax department, believes Rutger Hafkenscheid of VMW Taxand. He highlights a different way. July / August 2010
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UK considers ADR to resolve tax disputes
The tax authorities in the UK are looking at the effectiveness of ADR to resolve tax disputes. Lessons can be learnt from other jurisdictions who have previously implemented schemes, says Richard Doran of Dorsey & Whitney July / August 2010
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New exemption brings cheer for overseas employees
A 60-day wage tax exemption for foreign employees working in the Netherlands is welcome news for multinationals, say Dorine Fraai and Roxanna Windzak of Horlings, a member firm of Nexia International July / August 2010
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Italy steps up evasion campaign
Maricla Pennesi of DLA Piper analyses why the Italian tax authorities have become more aggressive recently in the fight against international tax evasion July / August 2010
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European awards winners take their prizes
The Alliance of Gleiss Lutz, Herbert Smith and Stibbe won the European Tax Firm of the Year for the first time at International Tax Review's European Tax Awards in London. July / August 2010
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Tribunal causes surprise with transparency decision in Swift
The UK's First Tier Tribunal decision in Swift determined, contrary to the accepted position, that a Delaware LLC is transparent for UK income tax purposes. Though the decision does not set any binding precedent, William Arrenberg of Herbert Smith believes it has wider implications than many appreciate July / August 2010
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Beware Circular 698 on indirect transfers
Released only eight months ago, China's circular 698 caused much controversy as it gave the tax authorities the power to investigate transactions dating back to 2008 while requiring taxpayers to report any indirect transfers within 30 days of completion. But with many not paying attention to the circular, Jack Grocott investigates how an influential court settlement is likely to make taxpayers think twice about ignoring the circular. July / August 2010
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European heavyweights see common tax base as key to single market
The report by Mario Monti into how to complete the EU single market lends some support to the plans of Algirdas Semeta, European commissioner for tax, for a common corporate tax base. Salman Shaheen spoke to both men and other observers about the likelihood of the concept becoming reality July / August 2010
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Getting things done
September 2010
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No way to run a tax system
July / August 2010
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Italy removes Cyprus and Malta from CFC blacklist
September 2010
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Commission rejects news of European taxes
September 2010
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China's reorganisation circular fails to address concerns
September 2010
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US jobs bill including $11 billion in international taxes becomes law
September 2010
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US makes changes to business compliance
September 2010
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Changes to Luxembourg's corporate tax regime
September 2010
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East African budgets bring tax changes
July / August 2010
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Tax authorities' claim Vodafone warned of $2 billion tax bill
July / August 2010
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Chancellor announces corporate tax cuts
July / August 2010
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China claims biggest 698 victory
July / August 2010
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Calls go up for a price on carbon
July / August 2010
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Senate kills tax extenders legislation
July / August 2010
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Japan's ruling party proposes tax cut
July / August 2010
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Switzerland rejects UBS deal with US
July / August 2010
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RSM Tenon appoints new directors
September 2010
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McClellan moves to General Electric
September 2010
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Miller & Chevalier hires Kirschenbaum
September 2010
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Simpson leaves ATO
September 2010
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Baker & McKenzie adds new partner
September 2010
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Deloitte Middle East launches indirect tax practice
September 2010
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Tognetti joins BPGM
September 2010
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TEI announces new president
September 2010
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KPMG changes US tax leaders
September 2010
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Grençon joins PricewaterhouseCoopers
September 2010
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DLA Piper appoints new UK head of tax
September 2010
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People
July / August 2010
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Tax Relief
A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com September 2010
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Tax relief
A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com July / August 2010
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