Magazine
June 2011

Magazine Archive

Reports of African audit for SABMiller are premature
EU: VAT neutrality divides EU conference
Japan should increase consumption tax
Irish Revenue to audit TP this year
Pakistan mulls documentation requirements
Thailand: Questionnaire is more trouble than financial statement
Revenue’s win in Tower MCashback could create uncertainty
China seeks corporate whistleblowers
Netherlands: EC challenges VAT top holding companies
Clifford Chance adds new partners
SJ Berwin promotes Paris partner
Baker & McKenzie moves tax partner to Gulf
Gide Loyrette Nouel promotion
DLA Piper strengthens European tax team
Grant Thornton adds to corporate tax practice
McDermott Will & Emery opens in Paris
Tax Executives Institute elects new president
Chief judge champions US tax court’s approach

Lawyers used to practising in US district courts may be surprised to see that things are done differently in the national tax court. In an interview at the court in Washington DC, Chief Judge John Colvin explains to Erin Kelechava that the tax court places a greater emphasis on pre-trial procedures in the hope of achieving a more efficient resolution of the case on the merits.
Joint audits show promise of better compliance

The complexity of multinationals’ tax affairs has meant that there is a premium on tax information. This has led to initiatives aimed at increasing cooperation and coordinated action between and among tax administrations. As the tax audit landscape changes, with the beginning of joint auditing, Matthew Gilleard investigates whether two heads really are better than one.
Africa’s transfer pricing commitment

A number of meetings have been held in recent months to discuss the future of transfer pricing in Africa. African governments, along with developed countries around the world, are proving their commitment to build up the transfer pricing systems in sub-Saharan Africa but a number of challenges stand in the way. Sophie Ashley builds a picture of transfer pricing today; how far has it come and how far does it need to go?
Asia directors unveil long list of concerns

After last month’s Asia Tax Executives’ Forum in Singapore, International Tax Review investigates the real issues Asian tax directors face on a daily basis as they experience greater scrutiny from authorities while at the same time finding their work being placed higher on their board’s agenda.
Just add water: Why European tax directors want new focus on stability, clarity and efficiency

As European economies emerge from recession and attempt to establish long-lasting plans for growth, Salman Shaheen finds out from some leading tax directors that while they welcome trends towards lower corporate tax rates, it is stability and clarity they want.
European Tax Awards

International Tax Review broke new ground last month with the presentation of awards for the leading in-house tax teams in Europe for direct and indirect tax.
US companies seek UK migration benefits

In recent years there has been a great deal of interest in corporate migrations out of the UK. But a non-UK group becoming UK headquartered is an area that has received somewhat less attention. Simon Letherman, Ansgar Simon, Don Lonczak and Iain Scoon of Shearman & Sterling in London and New York explore why US groups are attracted by inverting into Europe, and particularly the UK.
New Zealand levels rules on collective investment

Greg Haddon of Deloitte New Zealand runs through the latest tax rule changes for non-residents investing into portfolio investment entities.
The risky business of Canadian tax audits

Over the past decade or so, Canada has been struggling with the problem of how to effectively deploy their audit verification personnel in the face of increasing complexity in both the applicable domestic tax laws and the transactions and structures used by taxpayers. John Yuan and Chia-yi Chua of McCarthy Tétrault in Toronto explain how the Canada Revenue Agency have begun to employ some form of risk analysis to assist with their internal decision making on what type of taxpayers or issues to pursue.
Russia explains preparatory and auxiliary test

Boris Bruk and Evgeny Timofeev of Salans in Russia analyse the Bloomberg case and discover that the ruling will inspire further discussions about the framework of preparatory and auxiliary activities within the scope of the permanent establishment concept
Austria’s new approach to banking secrecy

Alexander Hofmann of Hofmann Law runs through Austria’s latest attempts to improve its banking secrecy and discovers that the country needs to make more concessions to global standards if it wants to shrug off its tax haven image.
Albania seeks EU tax law compliance
Withholding tax regulations
Bulgaria and Austria treaty enters into force
Increasing number of tax information exchange agreements
Cross-border reorganisations in Chile
Parliament approves new legislation on bank deposits
Ruling on Finnish CFC legislation
Case challenges French companies’ cash reserves
Court upgrades acquirer’s appeal rights against taxes on seller
Taxation on outbound income of bandwidth leasing
Amendments to Profit Tax Law
Mexico and Kuwait enter into tax treaty

During the ordinary session period that closed on April 2011, the Mexican Senate approved the tax treaty signed between Mexico and Kuwait.
Postponed payment of tax liabilities on corporate income tax
Court of Appeal rules that a commissionaire company constitutes an agency PE of its principal company
Foreign collective investment vehicles exempt from Polish income tax
Romania: Interest & Royalty Directive: Application and interpretation of facts
Amendments to property tax law
US Inbound: Foreign bank account final regulations released
US Outbound: Treasury issues final section 904(d) regulations
Tips to survive your Vietnamese transfer pricing audit
Tax Relief