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  • M&S opinion keeps Europe guessing

    The opinion of the advocate-general in the Marks & Spencer (M&S) case at the European Court of Justice (ECJ) backs up the UK retailer's argument for cross-border group relief within the EU. But confusion remains about how the opinion will shape the final judgment and how national governments will react. Ralph Cunningham and Simon Briault investigate


  • Inside thinking from the US tax reform panel

    In an interview with Sed Crest in Washington, DC, Senator Connie Mack, chairman of the President's Advisory Panel on Federal Tax Reform, revealed his thoughts on how to reform the US tax system

  • Budget brings in corporate tax rate cut

    The 2005 South African Budget was not as dramatic in tax terms as some recent ones. However. it still contained a number of significant company tax proposals, explains Anne Bennett of Deloitte

  • Innovative changes allow taxpayers to optimize global strategies

    The introduction of a notional interest deduction and 0% capital duty into Belgian tax law will boost the appeal of the country for international taxpayers, argue Kurt De Haen and Koen Cooreman of PricewaterhouseCoopers

  • A new way to resolve international tax disputes

    Sed Crest speaks with Secretary-General Tjaco van den Hout regarding the role of the Permanent Court of Arbitration in The Hague as an alternative way to resolve international tax disputes

  • Government makes progress with Reit proposals

    The UK-Reit discussion is firmly back on the government's agenda. Cathryn Vanderspar of Berwin Leighton Paisner examines where the UK is in the process, the main tax hurdles still to be surmounted and some of the opportunities that may arise

  • Taxpayer wins court approval for foreign tax credit

    The US Court of Federal Claims has upheld the taxpayer's claim for a foreign tax credit in the Guardian case. However, the government still has time to appeal the judgment, points-out Ernst & Young

  • Spain appeals to international investors

    A favourable tax regime exists now for international investors in Spanish finance companies. For example, no withholding tax applies on the yields derived from the investment, explain José Ignacio Jiménez-Blanco and José Ma Cusí of Clifford Chance

  • Clamping down on international arbitrage

    Some of the UK Finance Bill's anti-avoidance provisions against international arbitrage and excessive double tax relief transactions are widely targeted and poorly drafted, argue David Haworth and Helen Buchanan of Freshfields Bruckhaus Deringer

  • Dutch court rejects claim of free movement of capital

    The rules preventing the deductibility of certain costs for subsidiaries outside the EU or EEA do not breach European law, according to an Amsterdam court. Gerben Weening and Samad Laghmouchi of Deloitte explain the decision

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International Correspondents

International Correspondents