ITR Search | International Tax Review

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

Serbia: Taxation of non-resident companies on rental income gained from immovable property

Slobodan Mihajlovic Panayiotis Diallinas VAT has been in Serbia since 2005. The threshold for obligatory registration for VAT is approximately €40,000 ($55,000). The general rate of VAT is 18% and the same rate applicable on income gained from renting a property.

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

Mexico: Amendments to maquila rules will enter into force

David Cuellar Cesar Salagaray On June 30 2011, August 9 2011 and October 10 2011, modifications to the Miscellaneous Foreign Trade Rules were published in Mexico's official gazette. The tax effects for foreign principals (acting under a maquila structure in Mexico) have been a recurrent matter of discussion and analysis since its publication.

November 01 2011

France: Significant changes to the treatment of losses and capital gains on shares

Hélène Rives Alexa Lecoeur The Amended Finance Act for 2011 was voted after an unusually quick legislative process in September 2011. It contains two main measures for companies.

November 01 2011

Chile: Additional withholding tax applicable to the forgiveness of interest

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

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

The consequences of estimating assumed obligations

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.

November 01 2011

Search results for