Magazine
July / August 2004

Magazine Archive

US updates procedures on advance pricing agreements
New accounting standard for treatment of fixed assets
Officials reform tax system for real-estate trusts
Minister reveals Budget shock for banks and corporations
Rulings may limit ETVE future success
Finance Bill relaxes offshore funds regime
Congressional differences remain over internet tax freedom
Tax credits to change; taxpayer wins subpart F court verdict
Baker & McKenzie adds 12 Mexican tax partners
Sarbanes Oxley bites in Germany
German tax star makes a break for independence
How the OECD helps the global tax environment

By Jeffrey Owens, director, Centre for Tax Policy and Administration, OECD
ConocoPhillips faces tax fraud claims
ECJ rules against suspension of EU budget rules
Russia revises list of taxes
Poland calls for EU corporate tax harmonization
ECJ flexes its muscles over Belgian capital gains tax
Tax compliance takes centre stage in Russia
US and China negotiate to end semiconductor row
OECD, IRS to speak at Berlin event
High court backs retailer in UK VAT case
China piles pressure on foreign companies
US corporates welcome new international tax rules
Who's worked on the biggest deals
Structuring multinational groups in Europe

The number of EU member states increased from 15 to 25 on May 1 this year. In a single move, the opportunities to structure investments for multinational groups in Europe multiplied, according to Götz Wiese and Henrik Lay of Latham & Watkins
Transfer pricing reforms follow international practice

Colombia's new transfer pricing rules set out clearly what is expected of taxpayers, according to Ricardo Rosero, Bernardo Solano, and Fabián Alfonso of BaseFirma
Different ETI repeal bills mean difficult negotiations ahead

The US Senate and House of Representatives have passed legislation to repeal the ETI regime. Now lawmakers must confer to reconcile the bills’ differences, report Marjorie Rollinson, David Benson and Michael Mundaca of Ernst & Young
Tax efficiency features in new SICAR structure

New legislation aims to encourage private equity and venture capital investment via Luxembourg. Dean Rolfe of PricewaterhouseCoopers discusses the role tax plays in the new vehicle
Indian summer

When the largest democracy in the world unexpectedly changes its government, you might expect corporate tax directors to examine their strategies anxiously. But in an interview with Rupak Saha, country tax leader at GE in New Delhi, Simon Briault discovers a period of stability and optimism in India that has been unaffected by political change and looks set to continue
Israel launches trust tax amnesty

Taxpayers in Israel can avail of an amnesty on foreign trust income and gains up to the end of 2003. But the amnesty's disclosure requirements may put some of them off, according to Alon Kaplan and Lyat Eyal, of Alon Kaplan Law Firm and Leon Harris of Ernst & Young
What the new transfer pricing rules will mean

Gary Richards of Berwin Leighton Paisner explores the ramifications of the UK's new transfer pricing regime, particularly for foreign groups
Treaty highlights issue of participation exemption

A Brussels court has just ruled that a dividend of Hong Kong origin is entitled to Belgium's 95% participation exemption, according to Kurt De Haen and Magalie Delattre of PricewaterhouseCoopers
Cyprus modernizes tax legislation

A low tax rate and membership of the EU are part of what makes Cyprus attractive for corporate tax planning, believes Pavlos Aristodemou of Michael Kyprianou & Associates
Corporate bonds' exemption under scrutiny
Taxman demands directors attend to risk management
Rulings bid to clarify tax base
GAAR in Supreme Court and legislative spotlight
Accession forces Interest and Royalty Directive amendments
New way of claiming reduced withholding tax benefit
Tax authorities reject leading transfer pricing decision
Supreme Court rules on India-Malaysia tax treaty
Imminent changes to capital acquisitions tax