Magazine
September 2007

Magazine Archive

Developing Asia

The role of head of an in-house tax department is becoming an increasingly complex and challenging one to take on. Long hours, resource and talent shortages and ever-changing legislative landscapes are but a few of the challenges. Catherine Snowdon finds out why the situation for the tax directors of Asia is even more convoluted.

Finnish taxpayer loses at ECJ
Supreme Court clarifies tax position of foreign companies with outsourced services in India
Tax considerations in acquisitions of high-tech companies
Limitation of the tax deductibility of director's compensation payments
Government financial aid for investments in the audiovisual field
Tax treaty between Mexico and the Slovak Republic
Clarification on interpretation of term material employer
New rules on advance tax rulings
Blacklist for application of participation exemption for dividends
Changes to secondary taxation
NTS announces tax audit directive for 2007
New transfer pricing regulations
New proposed CFC legislation
End to tax dispute in relation to the deductibility of hedging costs from warrants
IRS identifies another cross-border event as ''listed transaction''
Cross-border hybrid instrument transactions to gain increased scrutiny during IRS audits
Who's worked on the biggest deals
E&Y tax leader joins Moss Adams
Mr Kleinbard goes to Washington
Grant Thornton recruits new transfer pricing leader
Markson quits Credit Suisse for the law
Sue Bonney to run KPMG Europe's integrated tax operation
New Irish tax president selected
Fried Frank tax attorney promoted to partner
Blumenthal goes to Mishcon
Taj adds three new partners
Alston & Bird gains DC international tax partner
BMR & Associates
Kim & Chang
Ernst & Young
Editorial
Tax treatment of fund managers under attack

Robert MacDonald and Robert Abel of Gide Loyrette Nouel challenge proposed new US tax rules for fund managers
A tax dilemma for the Irish

Richard Murphy argues that the news that Ireland is to review its corporation tax policies is welcome, but only if the parameters for debate are set appropriately.
German corporate tax benchmarks low tax states

Thomas Busching, of Squire, Sanders & Dempsey, looks at the downside of an attractive corporate tax rate
Doggett bill faces uncertain future

Representative Lloyd Doggett wants to alter significantly the way that US withholding taxes are computed on deductible payments made to foreign persons. Mike Patton, principal at Ernst & Young Los Angeles, explains why Doggett will not succeed
New Treasury team faces major collective challenge

Chris Wales examines the tasks ahead of the new team at the UK's Treasury
Vodafone CFC case set for another round
US priority guidance plan receives mixed response
South Korea extends tax benefit
New treaty for Australia and Japan
Then there were three
Under-fire Australian government announces draft tax reforms
Czech government wins corporate tax cut
Uganda's high telecoms taxes condemned
Barbados premier calls for UN taxation policy
Antigua engages US law firm for tax law rewrite
UK proposes changes to foreign profits taxation

James MacLachlan and John Fairley of Baker & McKenzie examine the UK government's thinking on the taxation of foreign profits
LNG and oil sands under attack

Risk is something that goes hand in hand with the oil and gas industry. Militants' guns in Nigeria, political tensions surrounding reserves in Russia and Venezuela and production uncertainty that paticipants must accept: the market faces it all. There is another challenger - the tax authorities. And as Catherine Snowdon finds out, they are raising the stakes
Learning to manage VAT risk

Christoph Schärer, in Zurich, and Harvey Mayne, in Frankfurt, from PricewaterhouseCoopers explains why VAT risk is a major threat to businesses in the EU
Sempra ruling ends divided tax bias

Sempra Metals won a landmark victory in the UK House of Lords in July. Clive Greenwood, joint head of partnerships and LLPs at Lewis Silkin in London, explains how a revenue interpretation was contrary to European law
Landmark rulings shape transfer pricing policy

KR Girish and Rohit Jain, of KPMG in South India, review the impact of key transfer pricing decisions for multinational companies
Case law against leveraged buyouts
Inheritance and gift tax repealed by Constitutional Court
Division 7A: an opportunity to rectify exposures
Excess profit of Belgian central entrepreneur exempted on 'stand alone basis'-principle
Specific tax incentives
Treaty shopping - the next chapter
Tax treaty signed between Costa Rica and Spain
Interpretation of the China - Hong Kong double tax arrangement
2008 tax reform targets business restructuring