Special Focus
Capital Markets

Special Focus Archive

Germany: German bank levy and the international context

Ulrich Ammelung of PwC highlights the challenges the German government faced when implementing its own bank levy and outlines how banks operating in numerous European locations with bank levies will seek opportunities to avoid double taxation while at the same time complying with the new rules.
India: India sustains capital markets development

Newer products and newer technology being used by the players in Indian capital markets have significant tax implications which investors must be aware of, believes Sunil Gidwani of PwC
Ireland: Tax changes ensure a bright future for finance in Ireland

As Ireland shows some signs of economic recovery, the government’s commitment to financial services, seen in some key changes to the tax system recently, augurs well for the sector, believe Conor Hurley and Alan Heuston of Arthur Cox
Japan: Article 63 exemption and investment manager licensing

Koichiro Ohashi, Koji Yamamoto and Yoshiyuki Omori of White & Case describe fund distribution in Japan and analyse the article 63 exemption from business registration requirements which is increasingly being used by offshore managers as a resource-saving technique to distribute securities in Japan, and recent amendments to the securities law in relation to fund distribution to professional investors.
Sweden: Swedish position on capital attribution will lead to double taxation

Sweden does not allow the attribution of capital to permanent establishments. It should change its position to help companies avoid double taxation, explains David Perrone of KPMG
US: Remarketing of unit securities and IRS guidance

The hybrid instruments generically known as unit securities were a favourite of many public companies during the past decade. Thomas Humphreys, Remmelt Reigersman, and Jared Goldberger of Morrison & Foerster look at IRS guidance.