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  • US case law: the rulings that count

    In a busy year, the US tax courts ruled on subjects ranging from foreign tax credits to related party borrowings. Daniel Berman and Jeffrey Korenblatt, Sutherland Asbill & Brennan LLP, Washington DC analyze the rulings and their consequences


  • German court bans secret comparables

    The Düsseldorf Regional Tax Court has prevented tax auditors from using secret comparables in transfer pricing studies. The decision also raises questions over the use of profit methods. Thomas Borstell and Michael Prick, Ernst & Young Düsseldorf, examine the decision

  • All change for big five in Latin America

    The big five accounting firms would like internal feuds to be invisible to the outside world. But in Latin America, disagreements have forced member firms to jump from one organization to another with alarming frequency over the last year. Oliver Ralph reports

  • China forces investment rethink

    The Chinese government’s economic reform programme has forced companies to re-examine their inward investment strategies. Joseph Tse of Deloitte Touche Tohmatsu in Shanghai advises on how multinationals can finance investment in the most tax efficient way

  • Colombian disasters squeeze tax

    A series of economic and geological crises have forced the Colombian government to expand the tax base through income tax and VAT changes. Publio Perilla of Gomez Pinzon & Asociados in Bogota explains the consequences for multinationals

  • Getting, having and holding

    The attractions of a career in industry are increasingly challenged by the big five who are beginning to market themselves as equally benevolent employers. Rosie Murray-West finds out what it takes to get and keep a top tax team

  • Reaping the benefits of US secondment

    Sending employees to the US has become a necessity for many multinationals, requiring careful planning of income tax and social security contributions. John Brantley and Doug Oas of Deloitte & Touche in London examine the opportunities available

  • Spain suffers APA teething problems

    The Spanish APA system was established three years ago, and has achieved some success. Amalia Gracia and Joaquín Velasco of Ernst & Young in Madrid discuss the difficulties faced so far and suggest ideas for improvement

  • US programme sets the standard

    The US APA programme is widely imitated and has become the benchmark for other jurisdictions. Steven Harris of KPMG LLP, Washington analyzes the reasons for its success and reviews the changes that could be on the horizon

  • Japanese APAs hit their stride

    The Japanese preconfirmation system has been around for 12 years – longer than even the US system. Akio Miyamoto, Dean Yoost and Greg Noble of PricewaterhouseCoopers in Tokyo discuss the system and the increasing popularity of bilateral APAs

News Analysis

  • Tax row blamed for German finance minister’s resignation

    German finance minister Oskar Lafontaine resigned from his post suddenly in March. Bonn officials gave no reason for his resignation, but the announcement followed an embarrassing forced revision of the forecasts for his tax reform plans.

  • Budget updates

    Hong Kong

  • Budget updates

    South Africa

  • Budget updates

    United Kingdom

  • Drug companies swallow Japan’s bitter pill

    Swiss pharmaceutical manufacturer Novartis is the latest company to feel the wrath of the Japanese authorities over transfer pricing. The Japanese government has fined Novartis' Japanese subsidiary, Ciba-Geigy Japan, ¥3.3 billion ($28 million) for underreporting its income by ¥8 billion between 1990 and 1994.

  • Belgium revamps stock options

    The Belgian parliament has approved radical changes to the taxation of stock options. The changes could make stock options more attractive to both businesses and their employees. The decision follows months of debate between tax professionals and the revenue authorities.

  • Freshfields gives focus to ex-Sidley partner

    Freshfields' New York office has attracted another tax partner from a top US law firm, just months after recruiting Gregory May from Milbank Tweed.

  • Australia lines up tax cuts

    A business tax committee in Australia has recommended that the corporate income tax rate should be lowered to 30%. The reduction would be financed by a broadening of the tax base. Industry has reacted positively to the proposals, but there is concern over the nature of some of the counterbalancing measures.

  • Tax grouping possible with non-UK companies

    Following the European Court of Justice's judgment in ICI v Colmer, the UK Inland Revenue has said that claims for group and consortium relief will now be accepted between UK-resident companies where a group or consortium is established by reference to companies resident in the European Union (EU) or the European Economic Area (EEA).

  • Further amendments to the Canadian imputation rules

    On March 10 1999, the Canadian government tabled a revised, detailed Notice of Ways and Means Motion modifying, in certain respects, the proposals relating to section 17 of the Canadian federal Income Tax Act contained in an earlier Motion tabled on December 10 1998 (see International Tax Review, March 1999).

  • Taxfax

    Simon takes partnership. Australians tax scouts, Forry makes the great leap, Nock is on the move again, Kuiper on the training run

International Correspondents