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The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.

On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.

According to Article 59 No 1 of the Chilean Income Tax Law (ITL), interest remitted abroad is subject to additional withholding tax.

The Authority for Advance Rulings (AAR) in the case of Columbia Sportswear Company [2011-TII-21-ARA-INTL], adjudicated on the taxability of procurement activity undertaken by a non-resident company through its liaison office (LO) in India.

The UK’s efforts to make the country’s tax system the most competitive in the G20 will end up costing the exchequer £2 billion ($3.2 billion) a year, says a senior HMRC official

Sean Foley Landon McGrew President Obama has released his plan to cut the US federal deficit by more than $4 trillion over the next decade, in part by undertaking tax reforms that are projected to raise approximately $1.5 trillion over the next 10 years. The plan, entitled the "Living within Our Means and Investing in the Future: The President's Plan for Economic Growth and Deficit Reduction" was released shortly after the President called on Congress to pass his $447 billion American Jobs Act. The President also released proposed statutory language for the proposals included in the plan. The deficit reduction plan includes a number of international tax reform proposals, all of which were previously included in the President's FY2012 budget – see our column President Obama releases FY2012 Budget, April 2011. The proposed international tax reforms included in the deficit plan would be effective for taxable years beginning on or after January 1 2013.

Vicente Bootello José Ignacio Ripoll In the last period of the present fiscal year, the government has introduced two significant changes in the Spanish tax system, concerning corporate income tax and wealth tax.

Sead Dado Salkovic To prevent consequences similar to those in the European countries regarding current debt crisis, the Montenegrin government plans to implement a number of economic measures by the end of the year, which will mostly concern public sector spending.

Rajendra Nayak Ganesh Pai The Authority for Advance Rulings (AAR) in the case of Columbia Sportswear Company [2011-TII-21-ARA-INTL], adjudicated on the taxability of procurement activity undertaken by a non-resident company through its liaison office (LO) in India. The taxpayer, a US company (US Co) engaged in worldwide wholesaling and retailing of outdoor apparel, set up a LO in India to act as a liaison for the purchase of the goods in India. The LO also assisted the US Co in procuring goods from Egypt and Bangladesh. The Indian Tax Law (ITL) provides for an exemption from income attributable to business operations in India, where the activity of a nonresident is limited to purchase of goods for the purpose of export (purchase exclusion). Also, under most tax treaties, a place of business maintained solely for the purpose of purchasing goods, or activities that are preparatory or auxiliary in nature, does not create a taxable presence/permanent establishment (PE) for the non-resident enterprise. The issue before the AAR was to determine whether the LO of US Co would come within the purview of the purchase exclusion under the ITL or not create a PE under the applicable India-US tax treaty.

Janne Juusela The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.