Magazine
October 2005

Magazine Archive

US will appeal WTO ruling on tax subsidies
Municipal business tax reduction planned
R&D incentives updated
Withholding tax on repurchased shares clarified
Deductions for losses on inter-company loans become more available
Advance pricing agreement programme launched
Value-added tax rules revamped
Transfer pricing documentation requirements clarified
Significant changes in transfer pricing legislation loom
New transfer pricing documentation requirements
Real estate investment trusts proposed
Dutch and UK treaties offer zero withholding tax on dividends held through hybrids
The proposed cost-sharing regulations and Xilinx
Two new partners arrive at Osler, Hoskin & Harcourt
Feyten moves up to partnership at Nauta Dutilh
Passarella takes over at Estudio Garrido
KPMG installs new tax management
Taj picks three new tax partners
Ten more countries join Taxand
IFA Congress exceeds expectations
Tax comes top again in New Zealand compliance study
Tax is only one part of proper repatriation programme
New tax research centre at Oxford
Abbey clears first hurdle in investment management VAT action at European court
French authorities scrap draft disclosure rules
One-stop shop VAT scheme will increase efficiency
Who's worked on the biggest deals
Definition of business purpose is central to Halifax decision

The impact of the ECJ decision in the Halifax case is likely to be different in different EU member states, according to Bob Jones and Luigi Lungarella of CLB Littlejohn Frazer
Transfer pricing audits get off to tentative start

India's tax authorities have completed the first year of transfer pricing audits. They need to clarify many issues before the system can be said to be working smoothly, argues Vispi Patel of Deloitte, Haskins & Sells
New law uses tax to promote energy sources

New energy legislation in the US extends tax breaks to operators of renewable projects in particular. Keith Martin of Chadbourne & Parke picks out the other taxpayers that will benefit from the law, that covers a range of energy sources, including nuclear
Conduit entity rules are key to IP planning

New rules on royalty conduit entities have implications for tax planning in the Netherlands involving intellectual property rights. Jos Peters of Rima Marlyn analyzes how the rules work and what issues litigation has highlighted
Courts exert more influence on tax system

An increasing amount of jurisprudence and the tax protocol to the CECA with India have been the features of tax developments in Singapore in 2005, according to Nand Singh Gandhi, Yeoh Lian Chuan and Lim Pek Bur of Allen & Gledhill
Time is running out for cash repatriation

Taxpayers must decide quickly about section 965 of the American Jobs Creation Act. Marjorie Rollinson, Michael Mundaca and Jose Murillo of Ernst & Young analyze the guidance the Treasury and IRS has issued to help taxpayers make up their minds
Savings directive fails ambitious target

The EU Savings Directive, which Luxembourg has recently implemented, aims to allow member states tax the savings income of its residents according to national rules. However, a number of loopholes may prevent this goal, points out Paul Chambers of Atoz
Exchange of information needs protection for taxpayers

Jeroen Adeler of Deloitte considers how the exchange of information agreements between the Netherlands Antilles, Aruba and the US can be improved to ensure that they protect the human rights of taxpayers
Debate over new incentives to reinvest profits
How foreign-resident trust beneficiaries can avoid capital gains tax
New transfer pricing audit centre requests information
Employee share plans become more flexible
Social security tax rules extended to Taiwanese, Hong Kong and Macau nationals
New thin-capitalization guidance released
The benefits of Dubai's tax treaties
Motorola, Ericsson and Nokia dispute PE decisiona
The tax consequences of transferring business from a branch

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October 2005

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