Direct Tax

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Czech VAT law scrapes through with injured minister’s vote

A parliamentary vote on the Czech Republic’s controversial value added tax (VAT) bill went ahead on April 22 2004 despite one of the key proponents of the bill being involved in a car crash
April 24 2004
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European Commission releases VAT fraud report
April 24 2004
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Baker McKenzie strengthens US transfer pricing team

Two more economists have moved from the big four to a legal practice in the US, adding to the movement in the transfer pricing services market there
April 24 2004
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Indian update: Supreme Court dismisses petition to review its decision allowing treaty ...

The Supreme Court of India has dismissed a petition made for reviewing its earlier decision on the validity of Circular 789 issued by the Central Board of Direct Taxes
April 24 2004
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Australian update: ATO commissioner warning over corporate governance and tax

The Australian commissioner of taxation, Michael Carmody, recently penned a letter to the chairperson of all publicly listed companies, reinforcing the messages in the document that he released in June last year - the...
April 24 2004
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US, UK, Australia and Canada set up tax taskforce
April 24 2004
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EU targets Germany’s exit tax regime

Germany could face proceedings in the European Court of Justice (ECJ) if it fails to respond to a European Commission (EC) demand to end its exit tax on unrealized capital gains of persons who leave the country
April 24 2004
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UK managers complain about increasing tax burden

A survey of business confidence among middle market companies in the UK has found real concerns within the sector over taxation and the administrative burden
April 24 2004
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US inbound update: New rules give greater flexibility after a tax-free stock acquisition

It is common in the US to acquire companies in tax-free stock acquisitions
April 24 2004
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Argentinian update: Capital gains on the sale of unlisted shares

Historically, Argentine-resident individuals have not been subject to domestic income tax on capital gains derived from the sale of shares, while foreign beneficiaries have been exempt under the provisions of Decree 2...
April 24 2004
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Tax officials raid Yukos offices
April 24 2004
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Russia increases oil companies’ tax burden
April 24 2004
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Law firm merger creates new tax practice

Wilmer Cutler Pickering and Hale and Dorr will combine on May 31 2004 to create one of the largest law firms in the US
April 24 2004
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Saudi Arabia approves corporate tax cut
April 24 2004
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Czech president vetoes VAT bill
April 17 2004
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Argentina unveils three-year tax plan
April 17 2004
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BT Group faces state aid complaint
April 17 2004
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Singapore gives tax breaks for accounting and law firms

The government of Singapore has extended tax breaks to Singapore-based audit, accounting, and law firms to strengthen the country's position as an international hub for headquarters operations and to encourage profess...
April 17 2004
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Brazilian Senate reconsiders import taxes for automotive and pharmaceutical companies

The Brazilian Senate is considering changes to the tax treatment of foreign imports to that could benefit companies in the automotive and pharmaceutical industries
April 17 2004
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Electricite de France takes tax dispute to the ECJ
April 17 2004
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OECD warns US over tax policy
April 17 2004
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Japanese update: Diet's US treaty ratification to bring new benefits

The Japanese Diet is expected to ratify the new treaty by the end of March 2004, allowing the treaty to become effective on January 1 2005 in general, except for the provisions relating to withholding tax on dividends...
April 17 2004
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Ireland hosts meeting of European tax heads
April 17 2004
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Tax boutique sets up shop in Switzerland
April 17 2004
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UK Finance Bill dismays corporate taxpayers

Tax specialists and corporate taxpayers have reacted with dismay to the unclear measures to introduce intra-UK transfer pricing regulations and a crackdown on tax avoidance schemes in the UK Finance Bill
April 17 2004
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Indonesian tax authority shuffles staff
April 17 2004
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Australia introduces third round of tax reform

The Australian government has proposed its latest reforms of the country's international tax system with the introduction of the New International Tax Arrangements (Participation Exemption and Other Measures) Bill 200...
April 17 2004
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Irish update: What the new Finance Bill will mean

The increasing complexity and range of tax rules affecting international business require sophisticated and dynamic tax infrastructures in order to deliver global tax objectives
April 17 2004
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Turkey plans tax incentives for foreign investors
April 17 2004
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Brazilian update: New decisions on social contributions PIS and COFINS

The government introduced many important changes at the end of 2002 to the programme for social integration (PIS) and, at the end of 2003, to the contribution for the financing of social security (COFINS) regulations
April 17 2004
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Glaxo challenges $2.7 billion transfer pricing claim

GlaxoSmithKline Holdings on April 2 2004 filed a petition in the US Tax Court contesting a multibillion-dollar transfer pricing claim
April 17 2004
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Australia introduces third round of tax reform

The Australian government has proposed its latest reforms of the country’s international tax system with the introduction of the New International Tax Arrangements (Participation Exemption and Other Measures) Bill 200...
April 10 2004
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Korb appointed chief counsel of the IRS
April 10 2004
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Baker & McKenzie steals transfer pricing economists from big-four firms
April 10 2004
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Tax authorities in the US continue pressure on tax evasion
April 10 2004
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Spanish update: Research and development credits expand

The Spanish CIT law has been reformed for tax years commencing on 2004, to further improve the tax credits for research and development (R&D) and innovation activities.
April 10 2004
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Glaxo challenges $2.7 billion transfer pricing claim

GlaxoSmithKline Holdings on April 2 2004 filed a petition in the US Tax Court contesting a multibillion-dollar transfer pricing claim. The US Internal Revenue Service (IRS) made its claim in January against Glaxo US, ...
April 10 2004
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US outbound update: IRS withdraws foreign tax credits notice

In 1998 the IRS and the Treasury Department got the attention of the outbound international tax community by issuing Notice 98-5. The notice sought to challenge certain tax-motivated transactions that generated foreig...
April 10 2004
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Finland implements EU tax directives
April 10 2004
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US Senate narrows debate on ETI repeal
April 10 2004
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EU update: French exit tax incompatible with EC Treaty

The European Court of Justice ruled on March 11 2004 that the French legislation taxing unrealized capital gains simply because a taxpayer moves to another EU member state infringes the freedom of establishment (case ...
April 10 2004
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Ford chief supports higher fuel taxes
April 10 2004
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Slovak parliament overrides presidential VAT veto
April 10 2004
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Singapore gives tax breaks for accounting and law firms

The government of Singapore has extended tax breaks to Singapore-based audit, accounting, and law firms to strengthen the country’s position as an international hub for headquarters operations and to encourage profess...
April 10 2004
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German update: High Court raises the bar for subject-to-tax clauses

In the May 2002 issue of International Tax Review (page 58), we reported on a decision by the Cologne Tax Court interpreting language contained in article 23(3) of the former tax treaty between Germany and Canada as a...
April 10 2004
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Slovakia stalls on VAT law

The president of Slovakia, Rudolf Shuster, has refused to sign the value added tax (VAT) law agreed by parliament ahead of the country’s accession to the EU on May 1 2004
April 03 2004
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Norwegian proposals benefit inter-company transactions
April 03 2004
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Global corporate tax rates fall
April 03 2004
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UK update: Tax implications of international accounting standards

Any company considering the adoption of international financial reporting standards (IFRS) will need to consider the tax implications of such a move. In the UK, the main tax area likely to be affected is financial ins...
April 03 2004
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Poland adopts indirect tax laws to comply with EU
April 03 2004
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Clampdown on IP leaseback deals

The New Zealand government is taking action against companies that might be tempted to avoid tax by entering sale and leaseback deals on their intellectual property
April 03 2004
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Chairman Thomas blames corporate lobby over tax Bill delay

US House Ways and Means Committee chairman, Bill Thomas, has blamed lobbying from Microsoft, Boeing and Caterpillar for delaying progress on his Bill designed to replace the export tax credits legislation averting $4 ...
April 03 2004
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Mexican update: Decree introduces maquiladora holding companies

On October 13 2003 President Fox issued a decree (the New Decree) that reformed the previous Decree for the Promotion and Operation of the Maquiladora Export Industry (the Decree) issued in 1998
April 03 2004
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Vodafone under pressure over VAT
April 03 2004
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US receives support for WTO complaint over Chinese VAT
April 03 2004
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UBS focuses on tax risk control

Oliver Bartholet, the head of tax for UBS, the Swiss bank, has identified transfer pricing arrangements as the chief area of risk for tax directors and says that their enforcement and documentation will be one of the ...
April 03 2004
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US Treasury forces the pace on tax-adviser standards
April 03 2004
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New Zealand tax change to lure R&D investment

Overseas investment in New Zealand’s burgeoning biotech sector could be boosted by a tax change aimed at helping the country compete with Australia for venture capital
April 03 2004
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ABA urges Congress to simplify US tax laws
April 03 2004
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Pillsbury Winthrop welcomes returning tax partner
April 03 2004
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French update: New withholding tax exemption case

In a decision dated November 3 2003 (Conseil d'Etat, 244437, SARL Meridia France), the French Administrative Supreme Court had to decide whether the interest paid by a French company to a partner domiciled abroad as c...
April 03 2004
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Canadian update: What the new foreign affiliate changes will offer

On February 27 2004 the minister of finance released Revised Draft Legislation and Explanatory Notes (the new proposals) that contains significant changes to Canada's foreign affiliate regime
April 03 2004
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Germany clarifies limited liability company tax status

The German tax authorities released guidelines on March 29 2004 clearing up long-standing confusion over the classification of limited liability companies (LLCs) for tax purposes as either a partnership or a corporation
April 03 2004
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KPMG pioneers corporate e-filing in the UK

KPMG piloted the UK’s first fully electronic system for companies to approve and file their corporation tax returns over the internet in late March 2004
April 03 2004
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US Senate approves tax treaty with Sri Lanka
April 03 2004
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EU rejects Gibraltar’s tax proposals
April 03 2004

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