Magazine
December 2010 / January 2011

Magazine Archive

The blurring lines in tax planning

A company’s obligation to its shareholders is to minimise tax and a government’s, to its people, is to close the tax gap. Where does that leave tax planning? Sophie Ashley talks to government officials, taxpayers and advisers to uncover where the confusion lies in a changing environment.
Poll reveals challenges across Latin America

Executives responsible for the Latin America region often claim they have the most difficult job in the tax department. As Elizabeth Bearese discovers the results of International Tax Review’s Latin America Client Services Poll seem to justify the claim.
Advisers are in the IRS’s crosshairs

The Internal Revenue Service (IRS) has uncovered thousands of suspected tax cheats through their long investigation into UBS. Between similar probes into other international banks, a new disclosure programme, and increased international cooperation, the agency is continuing its aggressive pursuit of those that hide assets offshore. Erin Kelechava investigates.
Agencies turn tax avoidance spotlight on companies

Development agencies have been lobbying governments and international bodies for years on the harmful effects of tax avoidance in the developing world. Now, as they turn their attention to the companies themselves, Salman Shaheen looks at their chances of convincing corporations that reputation is more important than a lower tax bill.
Technology targets tax risk reduction

Bob Norton, chief income tax officer at Vertex, argues that taxpayers have to realise that enterprise technology will be a necessity if they want to cut the risk of tax exposure.
Industry responds to OECD on withholding tax

In early 2010 the OECD released a discussion draft implementation package that provides for a streamlined withholding tax relief process. Paul Radcliffe of Citi looks at the industry responses to the proposals and explains why a consistent international approach to modernising rules in this area is vital.
Why tax authorities need to respect client privilege

Jason Collins of McGrigors and Don Korb of Sullivan & Cromwell explain why tax authorities need to respect client privilege and show how the US and UK handle confidential tax matters.
Awards honour complexity and innovation

The competition to provide advice of the highest quality to taxpayers in Asia was evident at the Asia Tax Awards, which were presented in Singapore on November 23 and which were attended by leading tax directors, officials and practitioners from throughout the region.
Italy explains treatment of debt into equity investments

With the release of Circular 42/E, the Italian tax administration provided clarification regarding the methods of application of article 113 of the Italian Tax Code. Fulvia Astolfi and Antonella Prencipe of Hogan Lovells explain.
France’s new leveraged acquisitions warning

France’s thin capitalisation rules are being drastically amended at the end of year in the 2011 Finance Act. Laurent Borey and Antoine Belgrand, of Mayer Brown argue that taxpayers need to pay close attention to these changes or face problems down the line.
How to manage risks in transfer pricing controversy

Tax authorities around the world are stepping up their enforcement of transfer pricing rules. It means taxpayers must prepare adequately to address any of their concerns, say Todd Wolosoff and Larry Powell of Deloitte
Amendments to the law on foreign investments
Thin capitalisation and transfer pricing
Changes to the IOF rates
Interest expenses and their deductibility
A welcoming appeal decision for non-residents of Canada
Income tax treaty with Denmark
Commission to propose CCCTB directive in strategy to strengthen single market and competitiveness
Court ruling on tax losses
IP/IT taxation regimes modified
Tax Bill 2010 includes CFC changes
Japan considers adoption of best method rule
Further VAT legislation changes
2011 Budget
DTAA between Mauritius and Bangladesh
Incentive for non-experienced workers
Tax treatment of agency services in Montenegro
Obligation to register for VAT for suppliers of electronic services
Thin capitalisation in Serbia
Highlights of the medium term budget
The code of good tax practices
Time to revise cross-border franchise contracts
Transfer pricing progress
Doing business in Ukraine is getting tougher
US Inbound: IRS clarifies status of check-the-box election for certain foreign eligible entities
US Outbound: IRS revenue procedure provides welcome guidance on check-the-box rules
Tax Relief - December/January 2011

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com
Dividend taxation presents tricky issues for Europe

Philippe Freund analyses some of the key dividend tax issues that have been raised in European cases recently, such as exemption versus imputation and the use of exchange of information provisions
Debate still continues on US carried interest

Richard Zarin and William Zimmerman of Morgan Lewis & Bockius investigate why the US Congress is having such difficulty passing carried interest legislation.
Corporate tax affairs taken to the streets

The series of demonstrations in November against Vodafone's alleged £6 billion ($9.5 billion) tax avoidance represent the first public protest about corporate tax in the UK.
Options available for UK tax simplification

Two organisations have offered different perspectives on simplifying the UK tax system in November.
New tax in Puerto Rico to proceed despite extreme opposition
HMRC pledges to close the tax gap
El Salvador tax declared “soak-up” by IRS
National sales tax to tackle US debt proposed
Czech Republic to tax solar energy
Honduras to introduce TP rules
Supreme Court turns down VAT appeal
Foster’s prepares to challenge ATO claim
Dechert adds to German practice
Freshfields gets new global head
McCullough leaves for Blake Dawson
A&O elects new global tax leader
Krogerus hires new head of tax
Nicolson to enhance KPMG on west coast
AGL Resources names new head of tax
KPMG adds to transfer pricing team
Lawyers launch new practice