Magazine
November 1998

Magazine Archive

UK GAAR wins few friends
NEW OBLIGATION TO WITHHOLD TAXES ON PAYMENTS TO NON-RESIDENTS
Kingfisher looks to Freshfields
First Active calls on Arthur Andersen
Bayer group turns to Cravath, Swaine & Moore
King & Spalding advises Lockheed Martin
Vendex looks to KPMG Meijberg
Nabarro Nathanson advises DEGI
Prudential Insurance turns to Cameron McKenna
Royal Ahold consults White & Case
Bain Capital consults Ropes & Gray
Allegiance Corporation calls on Davis, Polk & Wardwell
Linklaters advises Mobile Systems
AT&T looks to Wachtell, Lipton
Argentinian tax turn off for cable TV
Germany to overhaul taxes
Shipping to suffer in Norway budget
OECD sets principles for e-commerce
News in brief
Taxfax
US classifies software deals

After two years of discussion, the IRS has finalized the rules covering the classification of software transactions. Alan Levenson and Alan Shapiro, Deloitte and Touche LLP, San Jose & Washington DC, examine the consequences for software developers around the world
India adds to foreign tax burden

A recent ruling means that non-resident companies with a permanent establishment in India must now comply with the country’s minimum alternative tax policy. Jignesh R Shah, Price Waterhouse & Co, Mumbai analyzes the case and its implications
US courts get tough on schemes

Taxpayers who believe that their transactions are too complex for the revenue authorities to sort out should pay very close attention to recent IRS victories in the US courts. By Keith Martin, Chadbourne & Parke, Washington DC
Blueprint for UK APAs

Self-assessment for transfer pricing exposes taxpayers to several potential risks. In this context an effective APA system is vital. Robert Cole, Alston & Bird, Washington DC and Michael McGowan of Allen & Overy, London outline their recommendations.
US hybrids: the changing landscape

The second of two articles on the US check-the-box regulations examines the opportunities for investing from the US and the impact of recent changes. By Shawn Carson (BDO Seidman, New York), Allan Cinnamon and Zigurds Kronbergs (BDO Stoy Hayward, London)
IFA: more questions than answers

The 52nd IFA Congress, held in October this year, sported a new style. But was the substance and quality of debate enhanced? Phillippa Cannon sifts through the discussions to identify key questions and, in some places, even conclusions
Accounting for Colombian inflation

Tax planners ignore inflationary adjustments at their peril. Mario Andrade and Mario A de Castro, Deloitte & Touche Consultants, Bogota consider the accounting requirements for companies created by Colombia’s high rate of inflation
GAAR survey: Part One, Australia: Uncertainty rules in Australia

In part one of International Tax Review’s GAAR survey, Bill Orow of KPMG in Melbourne examines the Australian rules. Recent changes have done little to reassure worried tax directors and the introduction of a smell test has left a bitter aftertaste
GAAR survey: Part One, Sweden: Taxpayers left guessing in Sweden

Sweden has attempted several versions of a GAAR. However, the latest version still leaves taxpayers uncertain that it will be applied to their transactions. By Brita Munck-Persson and Thomas Lakhall, Mannheimer Swartling Advokatbyrå, Stockholm
Gaining credit in Germany

Though contrary to European law, foreign shareholders in Germany are prevented from claiming a tax credit available to German nationals. But, as Hans-Jörg Fischer of Clifford Chance, Frankfurt, explains, the courts may well assist foreigners to claim their full entitlement
Japan opens up debt securities

Changes to Japan’s debt securities regime have cleared the way for withholding tax exemption. Yusaku Ono of Hamada & Matsumoto, Tokyo advises on how non-residents and non-Japanese corporations can make the most of the new system
European supply chain strategies

European Monetary Union (EMU) will affect the European group on two levels - structural and technical. Ernst & Young's international tax group London examines some of the most striking of the structural business effects, and highlights technical pitfalls.
NEW CONCEPTS FOR RESIDENCE UNDER EXPATRIATE TAXATION PART II
Proposed Tax Measures of the Reelected Liberal Party
New Tax Treaty with the United States enters into force
German Taxation of Foreign Satellite Operators
Software rules redefined
Tax treatment of the Euro