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  • The 50 biggest influences in tax

    International Tax Review reveals its selection for the 50 biggest influences in international tax, with a mix of tax directors, officials, campaigners and multilateral organisations.


  • Surviving global meltdowns, terrorism and RBS

    James Badenach, former head of Asia tax at RBS, talks to Jack Grocott about how tax helped navigate the bank through the global meltdown and subsequent UK government bailout and why he is lucky to be alive.

  • Italy unveils regime change for taxation of financial income

    Nicola Saccardo of NCTM explains how different types of income from financial assets will be taxed in Italy.

  • Japan sets up special zones to lure R&D and HQs

    Japan is rolling out the red carpet for foreign investors in a bid to jumpstart its economy, which is struggling to recover from severe economic conditions triggered by the global financial crisis, the catastrophic earthquake and tsunami, and a strong yen. Hitoshi Takano, Jonathan Stuart-Smith and Linda Ng of Deloitte explain how newly created special zones and other tax incentives for companies may mean they consider relocating.

  • Dutch budget: complex tax legislation that goes too far

    On September 15 2011, the Dutch government published its 2012 budget proposals. The proposals include further limitations on the tax deduction of interest payments by acquisition holding companies and the introduction of a revised exemption for foreign branch profits. In addition, anti-abuse provisions are proposed in connection with the taxation of non-Dutch resident corporate shareholders in Dutch companies and the levy of dividend withholding tax on certain profit distributions made by Dutch co-operatives. René van Eldonk and Steven den Boer of Simmons & Simmons analyse the proposals.

  • Americas Awards 2011

    One of the few transfer pricing cases to go to trial in the US in the last decade won an Americas Tax Award from International Tax Review for Symantec, the taxpayer at the centre of the litigation.

  • The 50 biggest influences in tax

    International Tax Review reveals its selection for the 50 biggest influences in international tax, with a mix of tax directors, officials, campaigners and multilateral organisations.

  • Transfer pricing comes of age in Vietnam

    Transfer pricing activity has increased significantly in the past year in Vietnam with the government vowing to take the issue more seriously and investigate companies that are repeatedly reporting losses in the country. With a recent announcement of a pilot APA programme, Thomas McClelland, the chairman of EuroCham’s (European chamber of commerce in Vietnam) Tax and Transfer Pricing Committee, discusses what this means for businesses operating in the country.

  • Seeking efficiencies in the new IRS APA and MAP programmes

    As part of its continuing efforts to improve international operations, the US Internal Revenue Service (IRS) recently announced the reorganisation of its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes into a combined advance pricing and mutual agreement (APMA) programme. Kerwin Chung and Todd Wolosoff of Deloitte explain what the reorganisation, and its potential impact on taxpayers seeking APAs, will mean.

  • Brazilian tax litigation booms as economy grows

    Brazil’s economy, which expanded by 7.5% last year, remains an attractive prospect for foreign investors. Yet for those doing business in the country, the picture is not entirely rosy. Paying tax is becoming a much more difficult and precarious business. As the revenue authorities adopt a more aggressive stance, companies are increasingly facing the risk of controversy and litigation. Reuben Bard-Rosenberg investigates.

  • UK avoidance schemes and illegal insurance

    Providing a contract of insurance in the UK without the necessary permission or exemption is a criminal offence and renders the contracts unenforceable by the provider. Robert Viney of Davies Arnold Cooper offer some advice to ensure providers of avoidance schemes are on the right side of the line.

  • The consequences of estimating assumed obligations

    On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.

  • The benefits of VAT reduction on Spanish dwellings

    Royal Decree-Law 9/2011 has temporary modified the VAT rate applicable to first supplies of dwellings in Spain, which has been reduced from 8% to 4% until December 31 2011. The Royal Decree-Law justifies the measure for political reasons because of the specific economic situations and the considerable effects it is intended to produce. Eduardo Gracia and Ricardo García-Borregón of Ashurst look at who really benefits.

  • US taxpayers should not let their guard down on VAT

    Piet Vandendriessche and Nigel Mellor of Deloitte find that while VAT in the US is still unlikely soon, taxpayers should be alert to the possibility.

News Analysis

Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to

International Correspondents

International Correspondents