ITR Search | International Tax Review

Vietnam: New guidance on international bonds

Ronald Parks Recent guidance has been released, in the form of Circular No. 19/2011/TT-NHNN, specifying the process by which Vietnamese entities may issue international bonds, and the foreign exchange requirements arising from such issues. Corporate income tax and foreign contractor tax issues may arise as a result of international bonds issuances and more robust rules in this area may allow for new planning opportunities.

November 01 2011

Ukraine: Ukrainian tax authorities groundlessly strive to cut off tax losses

Vladimir Kotenko The Ukrainian tax authorities, in an attempt to increase tax revenues, have groundlessly opined that taxpayers cannot carry forward 2010 and older tax losses to 2011 tax returns prepared under the Tax Code. The development is an indication of a lack of improvement in the business environment and the authorities' attitude towards the taxpayers, despite the promises made by the government.

November 01 2011

Thailand: Recent cases of anti-avoidance in Thailand

Chinapat Visuttipat In recent years, the courts of both lower and higher courts have ruled in favour of the tax authorities. It is interesting to learn from the lessons of this development.

November 01 2011

Spain: Clawback and malus policies

As the global crisis spreads, public companies across the world are being targeted by a variety of recommendations and codes that are imposing best practices for new compensation.

November 01 2011

Romania: VAT and the transfer of a going concern

Jean-Marc Cambien The EU VAT Directive allows member states to treat, under certain conditions, a transfer of a totality or part of assets as an operation outside the scope of VAT. Such provision thus allows certain business reorganizations to happen in principle without a VAT cash flow impact.

November 01 2011

Canada: Residence not a prohibited ground of treaty discrimination

Janette Pantry Rebecca Levi A recent decision of Canada's Federal Court of Appeal considered the non-discrimination provision of the Canada-UK Tax Convention finding that it did not apply because the Canadian domestic legislation in question discriminated based on residency rather than nationality. The Federal Court of Appeal confirmed that Canada is not prohibited under the treaty from discriminating against taxpayers based on their residency.

November 01 2011

Albania: Albania-Ireland tax treaty enters into force

Eylem Philippou Drilona Likaj The income tax treaty that was signed back in October 2009 for the avoidance of double taxation and prevention of fiscal evasion between Albania and Ireland entered into force on July 12 2011 and will be applicable from January 1 2012.

November 01 2011

Finland: Ruling on life insurance saving agreement

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.

November 01 2011

Academics question effectiveness of EU transactions tax

Clemens Fuest has identified six objectives for the FTT

November 01 2011

Finland: Ruling on life insurance saving agreement

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.

November 01 2011

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