This content is from: Canada Canadian update: Supreme Court rules that interest expense is generally on account of c... The deductibility of interest expense is likely the tax issue on which the Supreme Court of Canada (the SCC) has commented most extensively August 29 2004
This content is from: Ireland Irish update: Imminent changes to capital acquisitions tax Capital Acquisitions Tax (CAT) is a tax imposed on gifts and inheritances (benefits), which exceed certain tax free thresholds August 29 2004
This content is from: United States US inbound update: Ruling restricts ability of foreign corporations to use US treaty be... Revenue Ruling 2004-76 held that a foreign corporation (A), formed under the laws of country X, could not claim the benefits of the income tax treaty between the US and country X if under the income tax treaty between... August 29 2004
This content is from: Mexico Mexican update: What the US social security covenant means The Mexican Institute for Social Security released on its website on June 29 2004 an agreement on social security contributions signed between the governments of Mexico and the US (the Social Security Covenant) August 29 2004
This content is from: Netherlands Netherlands clarifies transfer pricing guidelines Joop Wijn, the Dutch state secretary of finance, on August 21 2004 issued a decree clarifying how the Netherlands will apply the arm’s-length principle and the OECD’s transfer pricing guidelines for multinational comp... August 29 2004
This content is from: Direct Tax UK tax authority softens disclosure rules The Inland Revenue last week provided an assurance to tax advisers worried about the scope of the UK’s new tax disclosure regulations, which are designed to crackdown on the promoters of potentially abusive tax schemes August 29 2004
This content is from: Spain Spanish update: New tax framework comes into force A new Ley General Tributaria (General Taxation Law) was published on December 17 2003 (Law 58/2003) August 29 2004
This content is from: Direct Tax What tax directors want in Asia The cover story of the September issue of International Tax Review analyzes the responses from more than 380 tax directors, chief financial officers and other in-house tax executives doing business in Asia August 29 2004
This content is from: Saudi Arabia Saudi Arabia slashes corporate tax burden for multinationals Multinationals with operations in Saudi Arabia will benefit from a one-third reduction in their corporate tax burden (20% from 30%) after the kingdom’s Finance Ministry on August 15 2004 published changes to an income... August 21 2004
This content is from: Direct Tax Ceteris teams up with Transfer Pricing Associates Ceteris, the North American transfer pricing boutique, has announced a new alliance with Europe’s Transfer Pricing Associates August 21 2004
This content is from: Brazil Brazil reduces taxes on financial investments Investors in Brazil will get a better return on their money after the government reduced capital gains tax (CGT) on long-term financial investments and abolished social contribution taxes (PIS and COFINS) on financial... August 21 2004
This content is from: France French update: Substantiating the deductibility of intermediary commissions Commissions paid to intermediaries – with the exception of certain payments made to government officials within the scope of international transactions (section 39-2 bis of the French Tax Code) – are, in principle, de... August 21 2004
This content is from: Argentina Argentine update: Corporate bonds' exemption under scrutiny During the last decade, large Argentine companies were able to obtain access to medium- and long-term financing at attractive rates through the issuance of corporate securities (Obligaciones Negociables, ONs) August 21 2004
This content is from: New Zealand New Zealand piles pressure on banking industry New Zealand banks may have to pay more tax after internal government reports revealed that the country’s Inland Revenue Department (IRD) is concerned that they didn’t pay enough in 2003 August 21 2004
This content is from: Direct Tax Italian firm bolsters tax capability with boutique merger August 14 2004
This content is from: India India clarifies taxation of business process outsourcing The Indian Central Board of Direct Taxes (CBDT) released a draft circular last Mondaythat refines the hazy definitions over the taxation of business process outsourcing (BPO) by multinational companies August 14 2004
This content is from: Germany German regions reject centralizing tax collection Almost all of Germany’s 16 regional Länder have rejected calls to centralize tax collection in the country August 14 2004
This content is from: Latvia Latvian replaces Bolkestein as EU tax chief A Latvian with a reputation for euroscepticism will become the commissioner for taxation and customs union when the new EU Commission takes office on November 1 2004 August 14 2004
This content is from: Luxembourg Former Andersen team launches new firm in Luxembourg Last Tuesday a team of five former Andersen partners left Ernst & Young in Luxembourg to join a team of 30 to set up a high-end, new international tax firm called Atoz August 14 2004
This content is from: India Indian update: Supreme Court rules on India-Malaysia tax treaty The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty August 14 2004
This content is from: Australia Australian update: Taxman demands directors attend to risk management One of the most basic responsibilities of boards is to balance risk and return so that shareholder value grows and is protected August 14 2004
This content is from: Canada Canadian update: GAAR in Supreme Court and legislative spotlight Section 245 of the Income Tax Act (the Tax Act), enacted in 1988, contains a general anti-avoidance rule (the GAAR) that incorporates a modified business purpose test into Canadian tax legislation August 14 2004
This content is from: New Zealand New Zealand reforms goods and services tax Michael Cullen, New Zealand’s minister of revenue, has announced the start date for changes to the treatment of financial services under the country’s goods and services tax August 07 2004
This content is from: Argentina Ernst & Young loses Argentine tax head Guillermo Pérez, former national director of tax services at Pistrelli Henry Martin y Associados, Ernst & Young’s member firm in Argentina, has taken early retirement. August 07 2004
This content is from: Australia Ernst & Young loses senior tax partner in Sydney The big four firm has lost Richard Snowden who left to head up Henry Davis York’s tax practice. Snowden specializes in banking and financial services. Snowden cited restrictions in the US on accounting firms providi... August 07 2004
This content is from: Direct Tax Deloitte & Touche releases earnings for UK partners The success of Deloitte’s UK tax practice in the last year has boosted average partner profits across all the firm’s service lines. Figures released on August 5 2004 show that partners earned an average of £621,000 ($... August 07 2004
This content is from: Spain Spanish update: Rulings may limit ETVE future success The use of Entidad de Tenencia de Valores Extranjeros (ETVE)s by international investors has increased dramatically in the last few years. Both Spanish and non-Spanish newspapers and other publications have reflected ... August 07 2004
This content is from: United States New guidance on controlled foreign corporations earnings in the US The US Treasury and the Internal Revenue Service issued proposed regulations last Thursday providing guidance for determining a US shareholder’s pro rata share of income for controlled foreign corporations (CFCs) unde... August 07 2004
This content is from: Direct Tax Former Andersen partners plot new tax boutiques in the US New York is rife with rumours of two different groups of former Andersen tax partners looking to set up specialized corporate tax boutiques in the US. After the demise of Andersen in 2002, most the firm’s tax adviser... August 07 2004
This content is from: United States US outbound update: Tax credits to change and taxpayer wins subpart F court verdict Two months after announcing plans to address certain "inappropriate foreign tax credit transactions," (see International Tax Review, US Outbound Update, April 2004, p97), the US Treasury Department and the Internal Re... August 07 2004
This content is from: India Tax chief leaves Ernst & Young in India Mukesh Butani, Ernst & Young’s national tax director in India since June 2002, is leaving the position on August 15 2004 amid talk of turmoil at the firm. A number of partners, including Jairaj Purandare, Ernst & Youn... August 07 2004
This content is from: Japan Japanese update: New accounting standard for treatment of fixed assets The new accounting standard for the impairment of fixed assets will go into effect for fiscal years starting on or after April 1 2005. However, since early adoption was permitted for fiscal years ending on or after Ma... August 07 2004
This content is from: Belgium DLA builds tax strength in Brussels Marc De Munter, formerly a tax specialist with Freshfields joined DLA’s Brussels office last week. Joining the firm’s expanding tax practice, De Munter will work alongside Dirk Caestecker and Jeroen Gobbin. DLA is e... August 07 2004
