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  • Parent subsidiary directive: the long reach of Athinaiki

    The recent judgment of the ECJ in the Athinaiki case has possible implications outside its reference country of Greece. This article looks at how the decision could affect the tax systems of five other member states: the UK, France, Germany, Belgium and the Netherlands. By Patrick Tardivy, Martin Schiessl, Axel Haelterman, Michiel Sunderman and Roger Berner of Freshfields Bruckhaus Deringer in Paris, Frankfurt, Brussels and Amsterdam


Features

  • Parent subsidiary directive: the long reach of Athinaiki

    The recent judgment of the ECJ in the Athinaiki case has possible implications outside its reference country of Greece. This article looks at how the decision could affect the tax systems of five other member states: the UK, France, Germany, Belgium and the Netherlands. By Patrick Tardivy, Martin Schiessl, Axel Haelterman, Michiel Sunderman and Roger Berner of Freshfields Bruckhaus Deringer in Paris, Frankfurt, Brussels and Amsterdam

  • Transfer pricing at a time of economic downturn

    The US economy went into recession in March 2001. One year on, how and where is this reflected in transfer pricing? By Michael J McKee, Robert C Miall and W Scott McShan, Ernst & Young, North America and Europe

  • Is the UK going Dutch?

    The UK has abolished ACT on dividends and on certain royalty payments, introduced onshore tax credit pooling rules and is now proposing certain tax-free disposals of substantial shareholdings. In light of this Tim Sanders and Fintan Clancy of Skadden, Arps, Slate, Meagher & Flom, London, consider whether the UK is the new Netherlands

  • Canada targets transfer pricing transgressions

    Canada has an aggressive new agency determined to secure its share of international trade revenue. Substantial penalties and exhaustive audits await those who do not get their affairs in order at the earliest possible opportunity. By Hendrik Swaneveld, Martin Przysuski, Venkat Nagarajan and Sam Krishna, BDO Dunwoody LLP, Toronto

  • Have facts, will win in California

    Despite the state's aggressive reputation as a complex taxing regime, most California court cases are won and lost on the facts: this can give the taxpayer the advantage. By Eric J Coffill, Morrison & Foerster LLP, Sacramento

  • Mexico fudges tax reform 2002

    Rather than instigate a thorough process of reform, the Mexican Congress has opted for adjustments to the exisiting tax framework. Further change can be expected. By Miguel Valdez, Federico Aguilar and Lissett Tautfest of Ernst & Young, Chicago and Mexico City

  • New CGT regime for UK substantial shareholdings

    Where will UK companies fit in group structures when the UK capital gains exemption for disposals of substantial shareholdings takes effect in April 2002? Multinational tax planners take note. By Guy Brannan and Mike Hardwick and Lynne Walkington, Linklaters, London

  • Ireland continues to woo international business

    Ireland is continuing its efforts to be an attractive location for mobile international investors. New changes expected to be introduced the forthcoming Finance Act 2002 should continue this tradition. By Gary O’Mahony, Ernst & Young, Dublin

  • US loses appeal in ETI dispute

    US trade relations with the EU are put under pressure following WTO ruling, new guidance on check-the-box procedures are issued and APAs come under the spotlight. Hal Hicks, David Benson and Margaret O’Connor of Ernst & Young, Washington DC, look at the latest developments on the US tax scene

  • Tax gets a look in as SAB goes global


News Analysis



International Correspondents


International Tax Review Profile

Margrethe Vestager once again showing why she's in the #GlobalTax50 with today's announcement of an investigation i… https://t.co/ncyjcWUUE8

Dec 18 2017 01:07 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @JP_Owens: Delighted to see #WUGTPC featured in #GlobalTax50 by @IntlTaxReview https://t.co/CMax2lIkvU Congrats to other colleagues in…

Dec 18 2017 12:53 ·  reply ·  retweet ·  favourite
International Tax Review Profile

So, ITR readers. Will the US tax reform bill make it to Trump's desk by Christmas?

Dec 18 2017 11:17 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Competition: State aid: @EU_Commission opens in-depth investigation into the Netherlands' tax treatment of Inter IKEA https://t.co/b

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Commission: We have opened an in-depth investigation into the Netherlands' tax treatment of Inter IKEA, one of two groups operating…

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Correspondents