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  • Tackling tax avoidance: a delicate balance of legislation and corporate responsibility

    Multinational corporations have come under fire for aggressive tax avoidance. But their defence that their activities are legal raises an important question: Is it the responsibility of companies to act within the spirit of the law, or of governments to design better legislation to tackle avoidance? Salman Shaheen finds out what delicate balance is required.


  • Beneficial owner proposals: Not so beneficial

    There has been a significant rise in controversy around the world in recent years centred on the topic of the beneficial owner test which appears in the dividends, interest and royalties articles of most double tax treaties. Richard Collier, of PwC, explores the work of the OECD in this area to date and what the future holds, calling for greater clarity on the concept.

  • SOCIMIs: The last chance for Spanish REITs

    On December 27 2012, a significant amendment to the tax and legal regime of the Spanish Real Estate Investment Trust (REIT), or SOCIMIs (Sociedades Anónimas Cotizadas de Inversión en el Mercado Inmobiliario), was approved by the Spanish Congress following a proposal by the Spanish government. Javier Hernández Galante and Javier Mateos, of Ashurst, explain why they are optimistic about the changes.

  • The end of bank secrecy

    Algirdas Šemeta, European Commissioner for Taxation, Customs Union, Audit and Anti-Fraud, introduces the Directive on Administrative Cooperation (2011/16/EU) to increase transparency, improve information exchange and tighten cross-border cooperation, which he says are fundamental tools for fighting tax evasion.

  • UK: Corporate tax haven or hell?

    The UK is at the centre of a global debate on tax avoidance and the government is being pressed from all sides to make changes to the tax system. One significant change has been the announcement, in the Chancellor’s Autumn Statement, that the corporate tax rate will fall to 21% instead of 22% by 2015. But, amid complaints that multinationals are not paying enough tax in the UK, is this the right way for the government to go? Or is the UK becoming a tax haven for multinationals? Sophie Ashley talks to international tax practitioners about how the UK is shaping up and whether the government needs to change the law, rather than introduce different incentives, when it comes to multinationals’ operations.

  • Importance of tax contribution from UK business

    Some recent press coverage in the UK could suggest that business spends its time doing everything it can to dodge every tax it owes. But Richard Woolhouse, of the Confederation of British Industry (CBI), says the facts show how far from the truth this is.

  • Colombian tax reform on transfer pricing

    After a couple of years of work in preparing the tax reform Bill and several months of discussion and debate in the Colombian Congress, the government approved Law No 1607 on December 26 2012. With 198 articles, the law seeks to confront tax evasion in Colombia, as one of its main objectives. Diego González-Béndiksen De Zaldívar, head of DIAN’s (Colombia’s National Tax and Customs Direction) International Audit Unit, and Andrea Medina Rojas, an international auditor in the unit, describe the law’s process and what it will mean for taxpayers.

  • Third time lucky for French green taxes

    Jacqueline Cottrell and Constanze Adolf of Green Budget Europe explain why France should implement carbon-energy taxation.

  • VAT reform in China: impact on construction and real estate

    Lachlan Wolfers and Curtis Ng of KPMG explain what impact the Chinese VAT pilot will have on the construction and real estate sectors once it is extended to them.

  • Germany simplifies rule for repair services

    In practice, it is hard to determine whether a repair of movable tangible property is deemed to be a supply of goods, including installation, or a supply of services. Thus the Federal Ministry of Finance implemented a value ratio for the differentiation in its circular dated December 12 2012. However, caution is advised when applying this regulation, argue Thomas Küffner and Ronny Langer of küffner maunz langer zugmaier. It appears to be rather simple but is not applicable in every case.

  • Information sharing: How and why it is increasing

    Though we are only a few weeks into 2013, it is already clear that it will be a year in which cross-border cooperation and exchange of information reach new highs. Matthew Gilleard looks at how and why cross-border cooperation and information exchange are increasing, which jurisdictions are driving this, and what effects are already being seen.

  • Dividends give mixed holding companies a VAT headache

    The Conseil d’Etat recently handed down a judgment on the deductibility rules for input VAT on expenditure incurred by holding companies active in the management of their subsidiaries. Sonia Bonnabry, of LeXcom, analyses what the decision means for taxpayers.

  • Creating a tax risk management strategy for a multinational

    Managing tax risk is higher on the agenda for multinationals than ever before. One only needs to tot up the damning tax-related headlines in the mainstream press last year to see why. Lesley Holstead, who has spent much of her career helping multinationals manage tax risk, shares her experience in creating a successful strategy.

  • How to deal with debt-equity in the US

    The IRS is unhappy with multinationals exploiting cross-border differences in treatment of debt and equity for tax gains and is throwing more resources into preventing it. But Hewlett Packard, Scottish Power and PepsiCo were all challenged in the US Tax Court over debt-equity issues last year and two of them emerged victorious. Joe Dalton explains why such structures are still a valid and beneficial option for taxpayers and how to prepare your case if the IRS comes calling.

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