Direct Tax

Archive: Direct Tax

This content is from: United States

US Inbound update: Congressional differences remain over internet tax freedom

In October 1998, the federal Internet Tax Freedom Act (ITFA) was enacted calling for a three-year moratorium on state and local taxes on internet access
July 31 2004
This content is from: Direct Tax

UK’s tax disclosure rules take effect
July 31 2004
This content is from: Greece

Greece launches tax amnesty
July 31 2004
This content is from: France

French update: New way of claiming reduced withholding tax benefit

On May 25 2004 the French tax authorities released new administrative guidelines (Instruction 14 B-4-04) concerning the simplification of the procedure US partnerships need to follow to benefit from the French-US tax ...
July 31 2004
This content is from: Singapore

Singapore opens consultation on tax proposals

Taxpayers in Singapore will have until August 11 2004 to submit comments to the country’s finance ministry on proposed amendments to four major pieces of tax legislation
July 31 2004
This content is from: Italy

Italy introduces advance pricing agreements

The Italian tax authorities on July 28 2004 released details of the country’s new advance pricing agreement (APA) programme
July 31 2004
This content is from: Germany

Gibson, Dunn & Crutcher boosts German tax practice
July 31 2004
This content is from: Mexico

Mexican update: Officials reform tax system for real-estate trusts

As of January 1 2003, the Mexican tax authorities incorporated into the Mexican Income Tax Law tax incentives for Mexican real-estate trusts (MRET) where the primary activity is the construction or acquisition of real...
July 31 2004
This content is from: India

Taxpayers seek end to Indian outsourcing confusion

The Indian finance minister has promised to resolve the controversy over the taxation of business process outsourcing (BPO), such as call centres and back-office services, by foreign multinational companies
July 31 2004
This content is from: United States

IMF recommends the US increase taxes

In a report released last Friday in Washington, DC, the International Monetary Fund (IMF) has recommended broadening the US tax base for businesses including a federal sales or value-added tax and higher taxes on ener...
July 31 2004
This content is from: Germany

German update: Tax authorities reject leading transfer pricing decision

In February 2004, the German tax authorities issued a directive addressing the landmark transfer pricing decision rendered by the Federal Tax Court (FTC) on October 17 2001 (see International Tax Review, February 2002...
July 25 2004
This content is from: Direct Tax

Car companies face UK transfer pricing probe
July 25 2004
This content is from: United States

Tough talking from the IRS

Donald Korb, the new chief counsel of the Internal Revenue Service (IRS) in Washington, DC, told International Tax Review’s Sed Crest what taxpayers need to do to protect themselves and what they should expect from th...
July 25 2004
This content is from: Brazil

Brazilian update: Rulings bid to clarify tax base

The Brazilian tax authorities have for the past few months issued a number of rulings designed to preserve and/or modify the related tax base
July 25 2004
This content is from: Brazil

Brazil backs down over payroll taxes

President Inácio Lula da Silva has withdrawn a proposal to increase payroll tax to finance pensions after a storm of protest from business leaders
July 25 2004
This content is from: Direct Tax

New OECD guidelines on international exchange of tax information

The OECD’s fiscal affairs committee finalized new guidelines last Friday for the exchange of information between national tax authorities under international tax treaty provisions
July 25 2004
This content is from: Direct Tax

EU update: Accession forces Interest and Royalty Directive amendments

The Interest and Royalty Directive of June 3 2003 was amended at the end of April 2004 in the context of the EU accession of 10 new member states
July 25 2004
This content is from: Germany

Germany publishes final version of new thin capitalization rules
July 25 2004
This content is from: United States

Treasury releases tax priorities for next twelve months

The US Treasury and IRS released the tax priority guidance plan for the next twelve months yesterday in Washington, DC
July 25 2004
This content is from: India

Taskforce recommends lower taxes in India
July 25 2004
This content is from: Poland

Polish tax team breaks away from Ernst & Young

Tomasz Michalik, a former Ernst & Young partner specializing in value-added tax (VAT) and international tax, has set up a new tax advice firm called Michalik & Partners, taking many others with him
July 17 2004
This content is from: Direct Tax

UK update: Finance Bill relaxes offshore funds regime

The Finance Bill passing through Parliament now proposes some significant changes to the offshore funds regime (Income Tax Act 1988 part XVII chapter V), which should enable more offshore funds to be certified as havi...
July 17 2004
This content is from: Germany

Germany releases new thin capitalization rules
July 17 2004
This content is from: South Africa

South African update: Minister reveals Budget shock for banks and corporations

Though the Minister of Finance’s Budget presented in February was described as bland, there was a shock which will affect banks and corporates
July 17 2004
This content is from: Venezuela

Venezuela to reduce VAT
July 17 2004
This content is from: Direct Tax

OECD, IRS to speak at Berlin event

Caroline Silberztein, head of transfer pricing at the OECD, and Donald Korb, chief counsel of the US Internal Revenue Service, are two of the big names down to speak at International Tax Review’s Global Transfer Prici...
July 17 2004
This content is from: Direct Tax

EU moves towards harmonized corporate taxes
July 17 2004
This content is from: Belgium

Belgian tax amnesty fails to deliver
July 17 2004
This content is from: Mexico

Baker & McKenzie raids Ernst & Young’s Mexican tax practice

Eleven tax partners of Ernst & Young in Mexico have left the firm for Baker & McKenzie, the international law firm, decimating the big four firm’s tax practice there
July 17 2004
This content is from: Direct Tax

ECJ tax rulings increase pressure on national tax systems

The European Court of Justice (ECJ) ruled on July 15 2004 in favour of the taxpayer in two cases that could have broad implications for EU companies’ tax strategies
July 17 2004
This content is from: China

US and China negotiate end to semiconductor row

The US and China have ended their four-month dispute at the WTO over what the US alleged was China’s illegal support, through its tax system, of its indigenous semiconductor makers
July 10 2004
This content is from: Germany

German tax star makes a break for independence

Jürgen Hartmann, one of the most respected tax lawyers in Germany, has left the law firm CMS Hasche Sigle to set up his own practice
July 10 2004
This content is from: United States

US updates legislation on advance pricing agreements

The US Internal Revenue Service (IRS) issued updated procedures on July 1 2004 that taxpayers can use to request advance pricing agreements (APAs)
July 10 2004
This content is from: Russia

Russia proposes corporate tax changes
July 10 2004
This content is from: Germany

Tax client launches negligence claim against Haarmann Hemmelrath & Partner
July 10 2004
This content is from: China

China piles pressure on foreign companies

Tax officials in China have been stepping up efforts to combat tax evasion by foreign-invested companies that is estimated to cost the country Rmb30 billion ($3.62 billion) in lost revenue every year
July 10 2004
This content is from: India

GE’s India tax chief optimistic about tax system

Rupak Saha, country tax leader at GE in New Delhi, has delivered a positive verdict on the future of the Indian tax system in an interview with International Tax Review
July 10 2004
This content is from: United States

US corporates welcome new international tax rules

US multinationals and their tax advisers strongly support the overhaul of international tax rules, which is contained in bills which the US Senate and House of Representatives have passed in recent weeks
July 10 2004
This content is from: Direct Tax

Global task force against tax avoidance meets in secret
July 03 2004
This content is from: Direct Tax

Harrods boss loses appeal over special tax status
July 03 2004
This content is from: France

Vivendi Universal loses tax case
July 03 2004
This content is from: Direct Tax

High court backs retailer in UK VAT case

A test case brought by Debenhams, a UK retailer, could cost Customs & Excise as much as £300 million ($549 million) in lost revenue
July 03 2004
This content is from: Spain

Spanish update: What inheritance tax can mean for investors

When a non-resident individual is planning to make long-term investments in Spain, they should not forget to analyze the tax implications that may eventually arise for the heirs
July 03 2004
This content is from: Russia

Ernst & Young’s Russian tax chief moves on

Evgeny Astakhov, Ernst & Young’s head of international tax in Russia, has left the firm to join BP, the multinational oil company as general tax counsel
July 03 2004
This content is from: India

Indian update: Tribunal rules on professional services fees

The Mumbai Tribunal in Maharashtra State Electricity Board v. DCIT (83 TTJ 325), examined applicability of the old India-UK Double Tax Avoidance Treaty (DTAA), which was substituted by new DTAA in 1994, to fees receiv...
July 03 2004
This content is from: France

Morgan Lewis & Bockius launches French tax practice
July 03 2004
This content is from: Germany

Sarbanes Oxley bites in Germany

The US Sarbanes Oxley legislation, which prevents firms from providing certain tax services to audit clients and imposes strict rules to ensure auditor independence, is forcing tax advisers in Germany to consider thei...
July 03 2004
This content is from: Sweden

Sweden meets EU energy tax rules

The European Commission (EC) has ruled that Sweden’s amended energy tax system does not breach EU law
July 03 2004
This content is from: Japan

Japanese update: A new methodology for an arm's-length price

The new Japan-US tax treaty provides that the contracting states shall conduct transfer-pricing examinations of enterprises and evaluate applications for advance pricing arrangements in accordance with the OECD Transf...
July 03 2004

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