Direct Tax

Archive: Direct Tax

This content is from: Direct Tax

Tax lawyers claim privilege against UK disclosure rules

The future of the UK’s tax disclosure regulations could be in jeopardy after the Inland Revenue and The Law Society failed to reach an agreement on the impact of the regulations on tax lawyers that claim legal profess...
September 25 2004
This content is from: Japan

Japanese update: New real estate investment corporation amendments

Pursuant to the 2004 tax law amendments, a real estate investment corporation (J-REIT) can hold 100% of the preferred investment certificates issued by a Tokutei Mokuteki Kaisha (TMK)
September 25 2004
This content is from: Direct Tax

Irish update: Revenue opinions classify trading activities

Irish tax law provides for two rates of corporation tax
September 25 2004
This content is from: Brazil

Brazilian update: How the new transfer pricing methods will work

Law 9430 introduced the transfer pricing regime in Brazil on December 27 1996
September 25 2004
This content is from: New Zealand

New Zealand accounting firms’ tax advice to be legally privileged

Companies seeking tax advice from chartered accountants in New Zealand will get greater privacy after the country’s finance ministry announced new rules to level the playing field between accountants and lawyers
September 25 2004
This content is from: United States

US outbound update: IRS updates advance pricing agreement guidance

In two documents, the IRS has updated rules for getting an advance pricing agreement (APA)
September 25 2004
This content is from: Direct Tax

Tax breaks for UK film industry get cool response

The UK Treasury on September 21 2004 introduced a new package of tax breaks for the film industry, replacing the so-called section 48 incentives
September 25 2004
This content is from: Direct Tax

Olson to receive distinguished service award
September 18 2004
This content is from: New Zealand

New Zealand tax advice to be legally privileged
September 18 2004
This content is from: Hungary

Fiscal deficit will force Hungary to increase taxes
September 18 2004
This content is from: India

UK and Indian companies to benefit from changes to tax dispute procedures

India’s Central Board of Direct Taxes (CBDT) has issued an instruction that will benefit Indian and UK taxpayers involved in tax disputes under the two countries’ double taxation agreement (DTA)
September 18 2004
This content is from: Australia

Australian update: International taskforce targets package schemes

In recent years, eliminating abusive tax schemes has risen to the top of the agenda for revenue authorities, both locally and internationally
September 18 2004
This content is from: France

French update: The Hallminster case and the UK treaty

In the Hallminster decision (Case 250328), rendered on February 25 2004, the French Supreme Administrative Court had to decide whether a capital gain realized by a company resident in the UK from the sale of a majorit...
September 18 2004
This content is from: India

Indian update: Advance ruling on liaison offices

A recent Indian authority advance ruling (AAR) examined whether a liaison office (LO) of a foreign company constituted a permanent establishment (PE) in India
September 18 2004
This content is from: Direct Tax

Sarkozy continues attack on low corporate tax rates
September 18 2004
This content is from: Direct Tax

Baker & McKenzie expands UK tax practice

John Fairley, a former senior international tax partner at Ernst & Young, has joined Baker & McKenzie, the US global law firm, as a senior consultant in London
September 18 2004
This content is from: Argentina

Argentine update: What the new transfer pricing and thin- capitalization rules mean

The Argentine executive issued Decree No 916/2004 on July 23 2004, which provides clarification and new regulations to the provisions of last year's income tax reform introduced by Law 25.784
September 11 2004
This content is from: Italy

Italian update: New unclear substitutive tax rules on loans

The Italian market of medium and long-term loans (the Loans) is facing a great deal of uncertainty related to the substitutive tax applicable thereto (the Substitutive Tax)
September 11 2004
This content is from: Germany

German update: Thin capitalization rules finalized

Germany put new thin-capitalization rules into effect this year that are intended to conform to the requirements of European law
September 11 2004
This content is from: Finland

Manninen is another blow for national tax

The European Court of Justice (ECJ) struck out again at national tax systems throughout the EU last Tuesday, when it ruled that a Finnish man was entitled to a tax credit under Finland’s tax system on the dividend he ...
September 11 2004
This content is from: Direct Tax

New EU members reject criticism of corporate tax rates

The EU’s newest members have reacted angrily to criticism from Nicolas Sarkozy, France’s finance minister, that their low corporate tax rates are unfair
September 11 2004
This content is from: Austria

Austrian law firm sets up a tax practice

Clemens Hasenauer, an Austrian tax lawyer formerly at the top law firm Haarmann Hügel, has joined a rival firm as head of a new tax practice
September 11 2004
This content is from: Direct Tax

EU update: Imputation tax credits challenged before the ECJ

The European Court of Justice (ECJ) is likely to hold that shareholder relief on dividends in the form of an imputation tax credit is incompatible with the free-movement-of-capital principle under articles 56 and 58 o...
September 11 2004

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