July / August 2012

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Europe must lead the way

DFDL takes Winand from KPMG

DLA Piper partner joins Greenberg Traurig

New tax leader for Deloitte Luxembourg

Jeffrey Owens joins Ernst & Young

KPMG puts John McGowan in new global tax information role

Alvarez & Marsal expands on West Coast

Miller & Chevalier nabs Downing for criminal tax practice

Traub leaves House of Representatives for Deloitte

McDermott Will & Emery hires Antoine Vergnat

Deloitte adds 15 to partnership

New global head of tax for Freshfields

Hogan Lovells hires QC as new head of indirect tax

Batter returns to Baker & McKenzie

Sutherland adds two new partners to insurance tax group

Morrison & Foerster adds partner to NY tax group

Harger is latest to leave Dewey

Deals table

Unsealing of whistleblower CDs spells trouble for Julius Bär

Commission hails ETS compliance but airlines want plan B

Eaton’s move to Ireland highlights need for US tax reform

New York unleashes new tax enforcement tool

New rules complicate Germany anti-treaty shopping law

Guidance published for Irish securitisation companies

New Swedish limitation of interest deductions

Tax transparency: What it means for you

The tide turns towards country-by-country reporting

How the OECD is promoting tax transparency

Automatic information exchange – a new global standard?

Knowing when to be transparent in a tax dispute

The rise of transparency and corporate social responsibility

UK tax benefits of investment in infrastructure

PEs: Australian Treasury having second thoughts

Location saving on contract R&D arrangements

iXBRL Mandatory eFiling in the UK

How a mechanism to aid free circulation distorted EU market

What the future holds for Spanish VAT

Discrimination is not justified with investment funds

Recent challenges for inbound PE structures in Germany

Albania: Permanent establishment concept in Albania

Belgium: Changes to the new thin capitalisation rules

Belgium: Recent VAT developments in the real estate sector

Bosnia & Herzegovina: Bosnia & Herzegovina ratifies the double tax treaty with Malaysia

Brazil: Federal Senate unifies the VAT rate over interstate transfers of imported goods

Bulgaria: Taxation of ship operations

Canada: Canadian Budget 2012: Changes to foreign affiliate and thin capitalisation rules

Chile: Collective investment vehicles

China: China clarifies implementation issues with CIT incentives for western regions

Cyprus: Protocol to Cyprus – Austria double tax treaty signed

Czech Republic: Unrealised foreign exchange gains not income for Czech tax

Finland: Court ruling on transfer of losses in merger

France: Employee share schemes in an international context

Germany: Combating treaty/directive shopping

Hong Kong: Hong Kong progresses with DTAs and TIEAs

India: Ruling on taxability of transponder hire charges and dependent agent PE

Japan: Japan adopts earnings stripping rules

FYR Macedonia: Tax treatment of dividends

Mexico: Mexico’s miscellaneous tax decree

Montenegro: Transfer pricing regulations in Montenegro

Poland: Tax disputes on credit guarantees at no charge finally solved

Romania: Certain practical considerations on transfer pricing

Serbia: Serbia – Canada double tax treaty on income and capital

Spain: Spanish tax authorities deny characterisation as shares in income

US Outbound: IRS releases new foreign tax credit regulations

European Union: Two-step FTT likely to be adopted by December 2012

Tax Relief

Luxembourg: Preferential subscription rights: towards a clarified tax treatment

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