Direct Tax

Archive: Direct Tax

This content is from: India

Indian update: Taxes on expatriate allowances and benefits

In case of Hindustani Powerplus (141 Taxman 658), the Authority for Advance Rulings (AAR) examined the issue of tax implications of allowances and benefits given to expatriates deputed to India
January 31 2005
This content is from: Direct Tax

EU update: Amendment to EC Mergers Directive agreed

In December 2004, the EU Council of Ministers agreed on proposals to amend the EC Mergers Directive to improve the relief available to companies operating in Europe
January 31 2005
This content is from: Brazil

Brazilian update: Tax treaty with Spain clarified

The Brazilian tax authorities issued on December 23 2004 the Interpretation Declaratory Act (ADI 27, which is an official interpretation from the Brazilian tax authorities), setting forth their understanding in connec...
January 31 2005
This content is from: Direct Tax

Merged law firm strengthens international tax practice

Tracy Fisher, a former Hammonds tax partner, has moved to DLA Piper Rudnick Gray Cary, the international law firm that completed a worldwide merger agreement on January 1 2005
January 31 2005
This content is from: Direct Tax

EU releases R&D report

The European Commission has released a report that aims to encourage more research and development (R&D) and raise corporate awareness of the tax incentives that are available in member states
January 31 2005
This content is from: Japan

Japanese update: Tax reform on the way

The Ministry of Finance announced a tax reform plan for 2005 on December 19 2004
January 31 2005
This content is from: United States

GSK fights $5.2 billion IRS claim

GlaxoSmithKline (GSK), the UK-based pharmaceutical company, has received a demand for $5.2 billion in additional taxes and interest from the US Internal Revenue Service (IRS) over its transfer pricing calculations for...
January 31 2005
This content is from: Oman

Omani update: Value-added tax discussion underway

The government recently announced Oman's budget for 2005. The budget estimates a deficit of about $1.4 billion, which is based on a conservative oil price of $23 per barrel
January 31 2005
This content is from: France

French law firm boosts tax practice with Jones Day hire

De Pardieu Brocas Maffei, the French business law firm, has boosted its tax practice with the hire of an experienced tax lawyer from Jones Day
January 31 2005
This content is from: United States

Bush sets up panel on federal tax reform

President Bush signed an executive order on January 7 2005 to set up his Advisory Panel on Federal Tax Reform that will provide advice on ways to amend the US tax code including ways to encourage savings and investment
January 23 2005
This content is from: United States

US outbound update: IRS targets transfer pricing compliance

A new internal study by the US Treasury Department has confirmed that Internal Revenue Service (IRS) agents are demanding transfer pricing documentation in many more audits
January 23 2005
This content is from: United States

Boutique firm continues expansion with big-four hires

Ceteris, an independent transfer pricing and tax valuation boutique, has continued its expansion in the US by opening two new offices
January 23 2005
This content is from: India

India releases VAT plan

The government of India has released details of a key value-added tax (VAT) plan that will come into force on April 1 2005
January 23 2005
This content is from: Direct Tax

UK update: How the new disclosure requirements for VAT planning work

Businesses are now required to make a disclosure to HM Customs & Excise when they derive a UK value-added tax (VAT) benefit from the use of certain VAT-planning arrangements
January 23 2005
This content is from: Direct Tax

Transfer pricing is tax directors’ hot topic for 2005

Tax directors at large multinational companies believe transfer pricing will be their biggest tax issue in 2005
January 23 2005
This content is from: Switzerland

Swiss update: EU Savings Directive provisional guidelines released

On October 19 2004 the Swiss Federal Tax Administration published a draft of the guidelines of the agreement between the European Union and Switzerland regarding taxation of savings income in the form of interest paym...
January 23 2005
This content is from: Mexico

Mexican update: What the tax reforms will mean

The original proposal sent to the Congress to amend the Income Tax Law has suffered some changes regarding thin-capitalization rules that would enter into force on January 1 2005
January 16 2005
This content is from: Direct Tax

EU research reveals corporate tax worries

The European Commission believes that research it has carried out among 700 companies shows the need for a single EU-wide corporate tax base and a one-stop shop system for value-added tax (VAT)
January 16 2005
This content is from: Spain

Spanish update: What PE representatives are responsible for

An important (albeit often unnoticed) feature of Spanish tax law is the responsibility regime of representatives of permanent establishments and of foreign partnerships and similar entities with a presence in Spain
January 16 2005
This content is from: Direct Tax

KPMG hires Linklaters partner in London

Tom Scott, the veteran former Linklaters partner, has left the international law firm to join KPMG’s London tax practice
January 16 2005
This content is from: China

China to keep tax help for foreign companies

Multinational companies with operations in China will continue to benefit from the country’s tax system after the Chinese government pledged to keep preferential corporate tax treatment for foreign businesses until at...
January 16 2005
This content is from: South Africa

South African update: The scope of the revenue laws amendments

The Revenue Laws Amendment Acts was passed by parliament in November 2004
January 16 2005
This content is from: United States

US releases details on the profit repatriation window

Companies in the US are set to capitalize on a reduced tax rate for repatriated overseas profits after the US Treasury Department and the IRS on January 13 2005 provided new guidance on the American Jobs Creation Act ...
January 16 2005
This content is from: United States

Debevoise & Plimpton appoints new tax head
January 09 2005
This content is from: United States

US boutique expands tax practice with big-four hires

Berkowitz Dick Pollack & Brant (BDPB), a second-tier public accounting firm with two offices in the US state of Florida, expanded its international tax practice on January 3 2005 with the hire of Cary Cabañas, a forme...
January 09 2005
This content is from: Direct Tax

That was the year that was

The last year was notable for significant corporate tax reform in the US and Australia; judgments of the European Court of Justice continuing to dominate the discussion on the future of EU national tax systems and an ...
January 09 2005
This content is from: United States

Baker & McKenzie continues transfer pricing drive with US hire

Darrin Litsky, a senior US transfer-pricing specialist, has become the latest in a string of high-profile hires for Baker & McKenzie
January 09 2005
This content is from: Japan

Japanese update: Tax treatment of different business structures

There are various entity forms of doing business in foreign countries that exist between corporate form and the kumiai form
January 09 2005
This content is from: Italy

Italian update: What the Finance Act changes mean

On November 27 2004 the Italian government amended the proposed Finance Act 2005, by inserting significant changes to individual income tax (IRE) and proposing minor changes to the regional tax on productive activitie...
January 09 2005
This content is from: Ireland

Irish update: What the Mansworth v Jelley case means

The UK Inland Revenue’s interpretation of the decision in the case of Mansworth v Jelley (2003, STC 53) caused much debate in 2003 in the UK as the Inland Revenue surprisingly accepted the decision, even though it was...
January 09 2005
This content is from: United States

Ceteris hires Deloitte economist for new US office

Enrique Rayon, a transfer-pricing economist and former senior manager at Deloitte, has moved to Ceteris, the independent transfer-pricing boutique
January 09 2005

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