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  • osullivan.jpg
    Ireland: Exploiting intellectual property from Ireland
    IBM’s 2010 Global Locations Trends report ranked Ireland 1st in global inward investment per capita. This is a continuation of its ranking in previous years. Conor O’Sullivan of KPMG describes the factors that make it competitive to exploit IP in Ireland
    January 03 2012
  • moeytransfer150.jpg
    Alesco tax avoidance held
    The decision on intercompany debt funding has been made by the New Zealand High Court in Alesco New Zealand Ltd v CIR.
    January 03 2012
  • china150.jpg
    China unveils future for thin cap audits
    China has underlined its determination to strengthen its anti-avoidance rules by concluding the country’s first thin capitalisation audit.
    Jack Grocott, January 03 2012
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    Canadian Supreme Court confirms GSK date
    The Supreme Court of Canada has named the date for the GlaxoSmithKline hearing, which will finalise the long-running transfer pricing dispute.
    January 03 2012
  • European Union: EC plans to attack double taxation and double non-taxation in 2012
    On November 11 2011, the European Commission (EC) outlined its 2012 strategy for combating double taxation and double non-taxation in the EU.
    January 01 2012
  • Finland: Finnish government considers new tax incentives
    In October 2011, major Finnish trade unions and employers’ organisations agreed on the conditions of a new framework agreement. To support the tendencies of both parties, the Finnish government made suggestions regarding amendments in corporate and individual taxation.
    January 01 2012
  • Spain: Treaty and TIEA update
    Spain has concluded 83 tax treaties. There are 12 more tax treaties that have already been initialled or are awaiting parliamentary approval: Armenia, Azerbaijan, Belarus, the Dominican Republic, Hong Kong, Kuwait, Namibia, Nigeria, Peru, Senegal, Singapore and Syria.
    January 01 2012
  • US Inbound: President’s international tax proposals
    On September 23, President Obama released draft legislation for economic growth and deficit reduction. Provisions that could increase taxes on multinational corporations are an important part of the plan. The plan includes the following international tax proposals:
    January 01 2012
  • South Africa: Taxation Laws Amendment Bill
    The long awaited Taxation Laws Amendment Bill 2011 (Bill) was released on October 25 2011. This introduces various amendments, which are relevant in respect of cross-border transactions.
    January 01 2012
  • Germany: Inter-corporate dividend withholding tax hinders free movement of capital
    In a case brought by the European Commission (EC) (C-284/09 Commission v. Germany, judgment of October 20 2011), the European Court of Justice (ECJ) held that Germany’s withholding tax on dividends to other corporations is in breach of community law in that it discourages persons from abroad from investing in Germany.
    January 01 2012
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