This content is from: Direct Tax US-Inbound update: Cost-sharing regulations focus on stock options The Treasury recently finalized an amendment to its regulations on qualified cost-sharing arrangements (QCSAs) requiring that the deemed cost of stock options and other stock-based compensation be treated as a develop... November 30 2003
This content is from: Direct Tax Bonelli raids Deloitte & Touche for Italian tax launch November 30 2003
This content is from: Direct Tax New managing partner for Denton Salès Vincent & Thomas in Paris Dominique Derveaux, manager of the tax and structured finance practice at Denton Salès Vincent & Thomas, was appointed managing partner of the firm’s Paris office on November 17 2003 November 30 2003
This content is from: Direct Tax PricewaterhouseCoopers loses tax team in South Africa South African law firm Sonnenberg Hoffman Galombik picked up four PricewaterhouseCoopers partners on December 1 2003 November 30 2003
This content is from: Direct Tax Multinationals fail to retrieve advance corporation tax payments More than 70 multinationals failed to reclaim hundreds of millions of pounds from the UK Inland Revenue in a high court group litigation case on advanced corporation tax (ACT) November 30 2003
This content is from: Direct Tax EU update: ECJ confirms freedom of establishment On September 30 2003 the European Court of Justice (ECJ) ruled that certain obligations imposed by Dutch law on companies formed abroad but having their principal place of business in the Netherlands are incompatible ... November 30 2003
This content is from: Direct Tax Spanish update: Budget overhauls thin-capitalization and CFC rules The first draft of the new 2004 State Budget Bill that has been made public contains a couple of relevant changes to the rules on thin capitalization and controlled foreign corporations (CFCs) November 30 2003
This content is from: Direct Tax Ernst & Young critical of UK tax plans Ernst & Young has released its predictions for the UK pre-Budget report and warned that the government’s approach to UK tax issues could harm business and discourage investment November 30 2003
This content is from: Direct Tax Kuwait scraps corporate income tax for foreign businesses November 23 2003
This content is from: Direct Tax UK update: VAT victory for financial services outsourcing EDS has scored a victory in the Court of Appeal which, relying very heavily on European Court of Justice (ECJ) case law, has held that outsourced loan arrangement and execution services (in practical terms, representi... November 23 2003
This content is from: Direct Tax South Korea woos foreign business with tax reform proposals Falling levels of foreign direct investment have prompted South Korea’s government to propose significant changes to the country’s corporate tax regime November 23 2003
This content is from: Direct Tax Companies to lose favourable tax treatment in Luxembourg Luxembourg’s ministry of finance has published a draft bill amending the law on certain tax-exempt holding companies November 23 2003
This content is from: Direct Tax Ernst & Young loses US transfer pricing partner Ceteris, Inc, the independent transfer pricing boutique, has poached Sherif Assef, Ernst & Young’s financial services transfer pricing leader in New York November 23 2003
This content is from: Direct Tax France to offer tax breaks to expatriate executives November 23 2003
This content is from: Direct Tax Ireland Update: A flurry of double taxation agreements Ireland now has double taxation agreements (DTAs) with 41 countries November 23 2003
This content is from: Direct Tax Russia toughens stance on tax evasion The Russian government has closed a loophole in the country’s Criminal Code which allowed taxpayers with outstanding liabilities to avoid punishment if they agreed to pay tax arrears and fines voluntarily November 23 2003
This content is from: Direct Tax Brazil update: Export transactions can exclude social contributions Two Brazilian courts of first instance have issued important decisions relating to the application of the Brazilian social contribution on net income (CSLL) for income derived from export transactions November 23 2003
This content is from: Direct Tax Arthur Cox expands international tax practice Irish law firm Arthur Cox is expanding its international tax practice with the hire of Linklaters senior tax partner Conor Hurley November 16 2003
This content is from: Direct Tax Thailand focuses on transfer pricing compliance Thailand’s Revenue Department has reissued letters requesting taxpayers’ transfer pricing documentation to analyze and potentially challenge transfer pricing practices November 16 2003
This content is from: Direct Tax Kirkland & Ellis lures PricewaterhouseCoopers senior partner November 16 2003
This content is from: Direct Tax UK corporation tax consultations meet with criticism November 16 2003
This content is from: Direct Tax Italian update: Decree provides new opportunities This note is aimed at providing a first preliminary overview of the main changes to the Italian tax system addressed by Law Decree 269 of September 30 2003, effective as of October 2 2003 November 16 2003
This content is from: Direct Tax Finland boosts international tax competitiveness The Finnish government announced that it will cut the corporate tax rate to 26% and reduce the capital gains tax rate to 28% on November 13 2003. Both rates now stand at 29% November 16 2003
This content is from: Direct Tax Argentine update: Tax reform package targets international transactions In order to fulfil the government’s aim to introduce a series of measures to mitigate tax evasion, the Argentine executive has finally promulgated, on October 21 2003, a tax reform Bill where for exports of grain, hyd... November 16 2003
This content is from: Direct Tax Chinese update: VAT refunds on export sales to drop After rumours that the Chinese government would amend the VAT refund rates for export sales, the Ministry of Finance and the State Administration of Taxation jointly issued Notice on The Adjustment of Export Refund Ra... November 16 2003
This content is from: Direct Tax German update: What Bosal means in Germany The European Court of Justice (ECJ) rendered its decision in the matter of Bosal Holding BV on September 18 2003 November 09 2003
This content is from: Direct Tax Belgium’s tax amnesty fails to impress Tax payers have not responded well to the Belgian government’s tax amnesty to repatriate funds before the EU Savings Directive comes into force on January 1 2005 November 09 2003
This content is from: Direct Tax Torys expands in North America James Guadiana, formerly head of tax at the New York office of Davies, Ward, Phillips & Vineberg, joined Torys on November 4 2003, as part of the firm’s drive to expand in the region November 09 2003
This content is from: Direct Tax New benefits for minority shareholders in French demerger rules Under new regulations introduced on June 2 2003, minority shareholders no longer need to hold on to shares in demerged or spun-off companies for three years to avoid hefty taxes November 09 2003
This content is from: Direct Tax Australian update: New foreign exchange rules released Legislation introduced into the Australian Parliament on foreign exchange gains and losses – contained in the New Business Tax System (Taxation of Financial Arrangements) Bill (No 1) 2003 (TOFA Bill) – overhauls the t... November 09 2003
This content is from: Direct Tax Ernst & Young loses transfer pricing specialist to CMS in France November 09 2003
This content is from: Direct Tax Ernst & Young survey reveals a stretched UK Inland Revenue A comprehensive global transfer pricing survey carried out by Ernst & Young and released on November 5 2003 revealed that the UK Inland Revenue is lagging behind many of its international counterparts November 09 2003
This content is from: Direct Tax US Outbound update: Appointment of director highlights APA developments Much attention has recently been focused on the issuance of new regulations—the final regulations regarding stock-based compensation and proposed new regulations governing services—there has been no lack of important ... November 09 2003
This content is from: Direct Tax Savings Directive leads to new tax language for bond and MTN documents November 02 2003
This content is from: Direct Tax Multinationals fail to retrieve advance corporation tax payments More than 70 multinationals failed to reclaim hundreds of millions of pounds from the UK Inland Revenue in a high court group litigation case on advanced corporation tax (ACT) November 01 2003
