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  • Before and after M&A in China

    Foreign investors in China wishing to take advantage of the post-WTO business environment need to align clearly their business tax strategies and carefully adopt tax-planning techniques to optimize the tax position before and after the deal. By Billy Hsieh and Sandy Cheung, PricewaterhouseCoopers, Shanghai.


  • Treaty trumps domestic CFC rules

    In a ruling by the French High Tax Court, the provisions of the France-Switzerland treaty were found to override domestic CFC legislation. Marcellin N Mbwa-Mboma, of Baker & McKenzie, New York evaluates the case and its consequences.

  • Navigating Germany's stock option regime

    Stock options as a means of offering special incentives to employees have become increasingly popular in Germany in recent years. Dr Oliver Strnad, KPMG Tax and Legal, Stuttgart, overviews the present legal position regarding the taxation of stock options in Germany.

  • UK to overhaul corporate tax

    The UK government has published proposals aimed at further reform of UK corporate tax. In the future, it seems likely that all gains and losses from capital assets will be taxed in the same way as income. By Eric Tomsett, Deloitte & Touche, London.

  • Why the PATA proposal increases the compliance burden

    The Pata Package proposed uniform transfer pricing rules and guidelines to ease the compliance burden on members. However, the opposite may in fact be achieved, claims an international coalition responding to the proposals. Summarized by John Lyons and Albertina M Fernandez, Deloitte & Touche, Washington DC.

  • Get the most from French R&D credits

    France’s R&D tax credit regime offers substantial benefits for foreign investors. Make sure the relevant qualifying expenditure is properly documented from the outset, advise Isabelle MacInnes and Pascal D’Hont of Ernst & Young’s French Tax Desk, London.

  • UK tax leasing after the BMBF case

    The High Court decision in BMBF raises issues to be addressed by the UK leasing market. The importance of fulfilling the basic requirements for UK allowances when structuring the deal, seems to be a key lesson. By Hugo Jenney and Philip Vickery, Stephenson Harwood, London.

  • The best method for determining cost-sharing payments

    The US Internal Revenue Service has been putting forward the market capitalization approach as a tool for calculating buy-in payments for cost-sharing arrangements. Is this the best method? Jacqueline Doonan and Jessica Tien, Deloitte & Touche, San Francisco, have their doubts.

  • How to maximize group loss relief

    Group loss relief is a key tool used by taxing jurisdictions and companies to offset losses and encourage growth. But if group relief is to be a key method for business expansion, policies need to focus on bringing more subsidiaries under the group relief umbrella. By Abadan Jasmon and Dr Junaid M Shaikh, Multimedia University, Malaysia

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International Correspondents

International Correspondents