Direct Tax

Archive: Direct Tax

This content is from: Germany

Haarmann Hemmelrath tax lawyers cleared of negligence claims

The German tax authorities last week cleared Haarmann Hemmelrath, the prestigious German law firm, of any wrongdoing in a potentially harmful negligence claim relating to the tax work it did for one of its clients
November 28 2004
This content is from: Direct Tax

OECD delays permanent establishment guidelines

Businesses waiting for guidance on the attribution of profits to permanent establishments will have to wait longer than expected after the OECD delayed the release of its report on the subject
November 28 2004
This content is from: Direct Tax

Shell merger poses dividend tax treatment questions

The proposed Royal Dutch/Shell group share-swap merger of its twin holdings companies has required the Dutch tax authorities to approve a unique dividend access mechanism so that shareholders in the UK and in The Neth...
November 28 2004
This content is from: United States

McDermott Will & Emery reclaims PwC tax partner

Citing Sarbanes Oxley difficulties, tax partner Philip McCarty has left PricewaterhouseCoopers to rejoin, on November 8 2004, international law firm McDermott Will & Emery (MWE) in Washington, DC, where he worked unti...
November 28 2004
This content is from: United States

US outbound update: IRS says Societas Europaea is per se corporation

The Internal Revenue Service (IRS) has issued Notice 2004-68 adding several European business entities to the list of per se corporations
November 28 2004
This content is from: Direct Tax

New UK tax body to target avoidance

The official that recommended the amalgamation of the collection and administration of direct and indirect taxes in the UK has said that the new regime will target those who sought to avoid paying up
November 28 2004
This content is from: South Africa

South African update: Secondary tax on companies and non-discrimination

Dividends are generally exempt from income tax in the hands of the recipient shareholder in South Africa and there is no withholding tax on dividends
November 28 2004
This content is from: United Arab Emirates

UAE update: New Dubai International Financial Centre set up

On September 19 2004, the ruler of Dubai enacted the laws of the Dubai International Financial Centre (DIFC), a recent addition to the several free-trade zones already existing in the UAE
November 28 2004
This content is from: Brazil

Brazilian update: 0% withholding tax applies to extension of payment terms

On July 23 2004, provisional measure 183 was converted into Law 10,925
November 28 2004
This content is from: France

French update: Draft Finance Bill proposes new rules on company transfers

The draft Finance Bill for 2005 provides for an amendment to the French Tax Code with respect to the tax consequences of the transfer by a French company of its registered office to another EU member state
November 28 2004
This content is from: United States

US inbound update: Reorganization ruling has international ramifications

Revenue Ruling 2004-83 holds that the sale of one subsidiary to another subsidiary followed by the liquidation of the purchased subsidiary as part of an integrated plan qualifies as a reorganization under Internal Rev...
November 21 2004
This content is from: Spain

Spanish update: Spanish public companies must report on intra-group transactions

At the heart of discussions within the EU about excessive transfer-pricing documentation requirements being imposed on European multinational enterprises (MNEs), in recent times there has been an increase within the m...
November 21 2004
This content is from: Oman

Omani update: New income tax law proposed in Oman

The Ministry of National Economy is working on a new income tax law to replace the current legislation, originally issued in 1981
November 21 2004
This content is from: Greece

Greece slashes corporate tax rate

The Greek government plans to introduce a wide-ranging corporate tax bill that will cut the rate of corporate tax from 35% to 25% by 2007
November 21 2004
This content is from: New Zealand

New Zealand targets banks with thin-capitalization changes

Banks with operations in New Zealand face higher tax burdens after the government introduced a bill on November 16 2004 to radically tighten the country’s thin-capitalization rules for the banking industry, which has ...
November 21 2004
This content is from: United States

Deloitte reclaims top US Treasury official

Deborah Harrington, an attorney adviser in the US Treasury’s office of tax legislative counsel, has returned to the Washington, DC office of Deloitte, the big-four professional services firm
November 21 2004
This content is from: Mexico

Mexican update: Thin capitalization rules reach Congress

The tax authorities have sent the Congress a tax bill including proposed legislation concerning additional interest deductibility restriction to be effected through a series of thin capitalization rules that would ent...
November 21 2004
This content is from: United States

Tax reform debate gains momentum in the US

Abolishing the Internal Revenue Service and replacing taxes on income and investment with a flat national sales tax on consumption are some of the radical ideas gaining support in Washington, DC
November 21 2004
This content is from: Direct Tax

Kovacs confirmed as tax commissioner

The new EU commissioner for taxation and customs union is sticking to European Commission orthodoxy on corporate tax
November 21 2004
This content is from: Canada

Canadian update: Budget legislation tightens certain income fund proposals

Draft legislation was recently released by the Canadian Department of Finance to implement many of the measures announced in the government's March 23 2004 Budget
November 21 2004
This content is from: Italy

Italian update: Commission deems tax incentive to be illegitimate State aid

The Official Journal of the European Union of September 9 2004 contained the European Commission's invitation to submit comments to its letter to the Italian Government of May 7 2004 where it claimed that a certain It...
November 14 2004
This content is from: Direct Tax

UK government hints at cuts in business taxes

Gordon Brown, the UK Chancellor of the Exchequer, hinted last week that his government might reduce business taxes in an effort to ensure the country maintains its international competitiveness
November 14 2004
This content is from: Australia

Australian update: IFRS tax rules challenge thin cap safe harbours

A rapidly emerging issue is the impact that International Financial Reporting Standards (IFRS) will have on the thin capitalization "safe harbour" which is measured with reference to Australia's Generally Accepted Acc...
November 14 2004
This content is from: Direct Tax

EU update: European Commission suggests common consolidated tax base

During the ECOFIN meeting of September 10 and September 11 2004, the European Commission presented a non-EU-wide solution for profit determination rules for cross-border companies
November 14 2004
This content is from: Hong Kong SAR

Hong Kong proposes capital gains tax

Henry Tang, Hong Kong’s finance secretary, on November 1 2004 proposed the introduction of a capital gains tax to increase tax revenues, reduce Hong Kong’s spiralling fiscal deficit and broaden the tax base
November 14 2004
This content is from: Direct Tax

UK update: Inland Revenue changes disclosure arrangements significantly

The new UK tax disclosure rules, which oblige promoters and in some cases users of tax planning arrangements involving financial products or related to employment to notify details of the arrangements to the Inland Re...
November 14 2004
This content is from: Germany

German update: Germany revises international tax regulations

In May 2004, the German Federal Ministry of Finance issued an updated and revised version of the comprehensive regulations that guide the tax authorities in their application of the Foreign Transactions Tax Law (Ausse...
November 14 2004
This content is from: France

Baker & McKenzie poaches Landwell tax partner

The French tax practice of Landwell, the PricewaterhouseCoopers-affiliated law firm, has lost a high-profile, value-added tax (VAT) partner to Baker & McKenzie
November 14 2004
This content is from: United States

US to consider fundamental tax reform

After putting tax reform as a top priority in his campaign for a second term and winning greater majorities in the both the House of Representatives and the Senate, President George Bush looks well-placed to further a...
November 14 2004
This content is from: Direct Tax

Tax advice wins clearance from Three Rivers opinion

The UK Inland Revenue can not compel a tax lawyer to reveal advice he gives to a client after the House of Lords ruled on November 11 2004 that communications between a lawyer and his client qualify for legal professi...
November 14 2004
This content is from: Switzerland

Switzerland signs EU savings tax agreement
November 07 2004
This content is from: Direct Tax

Top executives take on more tax risk management

Tax risk management has become a key role for senior managers, who are taking more and more direct control of their organization’s tax strategy, according to an independent survey for Ernst & Young
November 07 2004
This content is from: Direct Tax

Lovells boosts tax practice with Mayer Brown hire
November 07 2004
This content is from: Direct Tax

Business wants results on tax anomalies

The leaders of the UK’s biggest companies have urged Gordon Brown, the chancellor of the exchequer, to take some “early action” to eliminate so-called “tax nothings” in the corporate tax system
November 07 2004
This content is from: Germany

Haarmann Hemmelrath boosts German tax practice

The Frankfurt tax practice of German law firm Haarmann Hemmelrath will be strengthened in January 2005 with the arrival of Joachim Krämer and Roderic Pagel, two international tax partners
November 07 2004
This content is from: Mexico

Mexican tax specialist returns to Ernst & Young

Koen van’t Hek, who left Ernst & Young at the beginning of July this year, has returned to the big-four firm
November 07 2004
This content is from: Direct Tax

Udre loses EU taxation job

No sooner was she in than she was out. Ingrida Udre, the original nominee as the new EU commissioner for taxation and customs union has been dropped from the European Commission president Jose Manuel Barroso’s revised...
November 07 2004
This content is from: Direct Tax

CMS expands into Spain
November 07 2004
This content is from: Denmark

EU forces changes to Danish transfer pricing rules

Kristian Jensen, the Danish minister of taxation, has published draft legislation to tighten the country’s transfer-pricing regime
November 07 2004
This content is from: Direct Tax

EU unhappy with US corporate tax bill
November 07 2004

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