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  • After years of negotiations between the Inland Revenue Department and the Institute of Certified Public Accountants of Cyprus, the Commissioner of Income Tax has clarified in writing the conditions that needs to be satisfied in back to back financing arrangements involving a Cyprus entity as intermediary company.
  • On August 19 2011, the Canadian Department of Finance released a package of proposed amendments including significant changes to the tax rules governing the taxation of income earned by foreign affiliates of Canadian taxpayers (the proposals).
  • Simeon Grigorov The definition of permanent establishment and the taxation of business profits are precisely inter-related and therefore can reasonably be considered common.
  • Edward Tanenbaum Tola Ozim On July 12 2011, Senator Carl Levin once again introduced his latest version of the Stop Tax Haven Abuse Act (Bill). Representative Lloyd Doggett recently introduced the same legislation in the House.
  • Mexico, with the largest treaty network in Latin America, signed a new tax treaty with Hungary at the end of June.
  • Agnieszka Bienkowska Polish VAT regulations faced a number of significant changes during 2011. Apart from the general VAT rise from 22% to 23%, on January 1 2011 some other new regulations have been implemented regarding such as taxation of financial and educational services, and causing that some of these services that used to enjoy VAT exemption in the past, now become taxed.
  • Speculation was inevitable when Mary Bennett, head of the OECD's Tax Treaty, Transfer Pricing and Financial Transactions Division in the Centre for Tax Policy and Administration, announced she was leaving, especially when the announcement came on the same day that Caroline Silberztein (head of the transfer pricing unit in the same division) handed in her notice.
  • Wendy Nicholls and Paul Smith of Grant Thornton UK welcome the new patent box proposals but believe the take-up may be limited because of the restriction to patents (rather than other intellectual property too), the highly complicated calculation of patent box profits, and potentially more favourable regimes within Europe.
  • The case can be appealed to the Court of Final Appeal The Hong Kong tax authorities will contest the Court of First Instance's decision in the Li & Fung case.
  • Radoslaw Szczech of Ernst & Young reviews some of the more important changes to Poland's VAT system, with particular focus on those that may offer interesting planning possibilities, both in terms of tax savings as well as simplification of administrative burden.