Magazine
July / August 2011

Magazine Archive

Tax scheme designed to make Melbourne world R&D capital
Costa Rica: Costa Rica proposes tax reform and moves toward OECD white list
India: OECD questions India over its tax treaty with Mauritius
China disregards documentation rules
OECD analyses TP simplification measures
Latvia: Taxpayers must supply TP information within one month
Transocean caught up in Norway’s biggest ever tax scandal
UK: BAA loses out in VAT claim after acquisition
Bödecker Ernst & Partner opens in Düsseldorf
Bonelli promotes two
McGrigors hires new directors
Busy times for PwC in the US
Leadership restructure at BMR
DLA Piper continues to expand
Weil Gotshal & Manges adds funds tax partner
Stibbe further expands new Luxembourg office
Baker & McKenzie gain tax disputes and TP partner
KPMG names new US TP leader
IRS transfer pricing director named
New KPMG financial services transfer pricing and indirect tax team
Colonel sheds light on Italian tax police

Chasing tax evaders, sharing intelligence and enforcing the law are all part of the day job for Stefano Gesuelli, head of Italy’s tax police. In an exclusive interview with Jack Grocott, he opens up to the workings of his unit and sends a warning to taxpayers that there is no place to hide.
Indirect tax in the dock

Following June’s Indirect Tax Forum in London, International Tax Review investigates the issues indirect tax managers face everyday. Environmental tax and VAT reform are high on their agendas while aggressive authorities are doing little ease their worries.
Europe's common tax base

How it could change your business
The long and winding road to a common tax base

After a decade of political discussion, negotiation and consultation, the European Commission has finally released its proposals for a common consolidated corporate tax base (CCCTB). Salman Shaheen finds out what the plans could mean for taxpayers and why they took so long to get to this stage.
CCCTB: the view from the member states

Each member state of the EU has its own corporate tax system. Some claim this complexity is clearly contrary to the aims of a single market and that at this time there is a greater need for member states to work together to stabilise the economic environment. But would the EU’s proposal for a CCCTB provide us with a simpler, improved system? Matthew Gilleard gauges the reaction from some of the member states.
It is transfer pricing but not as we know it

The CCCTB concept of relies on formulary apportionment, doing away with the arm’s-length principle (ALP). While many people welcome the opportunity to debate the future of tax compliance, others feel a switch to formulary apportionment will create just as many problems as the ALP. Sophie Ashley talks to the CCCTB’s critics and supporters about its impact on transfer pricing.
Why the US needs to pay attention to the CCCTB

US multinationals are not yet aware of the CCCTB’s potential impact on their business, but they should be. Although the goal of the plan is to reduce the compliance burden for companies, it may not simplify taxation for US groups that have operations in Europe. It is also likely to raise new tax issues for US entities. Erin Kelechava investigates.
How the Commission sees the CCCTB

Thomas Neale, head of the CCCTB Task Force in the DG Taxation and Customs Union of the European Commission, does not have an easy job as he is responsible for preparing the legislative proposal for the CCCTB. In an exclusive interview with International Tax Review, he answers the proposal’s critics and explains that taxpayers will benefit from the new regime.
France goes after local level profits and local expenses

The French requirements for transfer pricing documentation have to a certain extent secured the position of French subsidiaries. Multinational companies now face confusion from French tax authorities between the shareholders and management decisions. Financial consequences are huge. Isabelle Vendeville of Redlink investigates.
Russia enhances opportunities for investors

Since the beginning of 2010, Russia has been changing the shape of the Russian tax landscape for cross-border business. Julia Chernova, Evgeniya Chelysheva and Henri Prijot of Deloitte explain why these changes help make the tax system increasingly attractive to investors.
Beware of China’s tax anti-avoidance stance

Gary James of BDO in Hong Kong outlines changes to the approach taken by China towards anti-avoidance and urges taxpayers to critically consider their structures and practices.
Proposed amendments to Corporate Income Tax Act

Jean-Paul van den Berg and Johan Vrolijk of Stibbe describe certain corporate income tax matters included in a recent policy paper on the Dutch tax system that could affect cross-border transactions. They also analyse the legislative proposal regarding foreign currency results on exempt participations.
Amendments to Italian real estate investment rules

Fulvia Astolfi and Serena Pietrosanti of Hogan Lovells discuss recent developments in the Italian real estate rules and explain that while the changes will affect all aspects of the sector, many transitional provisions have been set up to minimise problems.
Norway’s exit tax and cross-border mergers challenged

The European Free Trade Association Surveillance Authority (ESA) has issued a reasoned opinion concluding that the Norwegian rules on exit tax for companies and cross-border restructurings are incompatible with the EEA agreement. Camilla Jøtun Borge-Andersen and Joachim Bjerke of BA-HR analyse the decision and discuss whether Norway’s response has resolved the issue.
Albania: Draft bill on Profit Tax Law suspended
Australia: Reportable Tax Position Schedule
Bosnia and Herzegovina: Capital gains taxation from financial instruments
Brazil: New regulation on Brazilian thin capitalisation rules
Bulgaria: Protection of holders of IP rights strengthened
Canada: New compliance obligations for payments to non-residents
Chile: Introducing new stock market MILA
Cyprus: Treaty ratified with Slovenia
EU: CCCTB directive status update and next steps
Finland: Ruling on taxation of board member compensation
France: Risk of double taxation on intra-group asset disposals come under focus
Germany: Wind farm depreciation
India: Taxability of data processing payments
Indonesia: Application of income assignment principles
Ireland: Ireland improves its R&D tax credit regime
FYR Macedonia: Amendments to Property Tax Law
Mexico: Mexico and Peru sign new tax treaty
Montenegro: Capital gains taxation in Montenegro
Romania: Service expenses deductibility: restrictions and solutions
Russia: Revision of the R&D expense deductibility rules in Russia
Serbia: New incentives in Serbia
South Africa: Draft tax law released
Spain: The secondary adjustment: a controversial institution
Spain: Anti-abuse rules must respect aim and tax treaty provisions
Ukraine: Tax reform is once again underway
US Inbound: Final anti-inversion regulations may revive business activity safe harbour
US Outbound: IRS announces selection of transfer pricing director
Vietnam: Has the abolition of freight tax simplified the taxation of shipping activities?
Tax Relief

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com