ITR Search | International Tax Review

Swiss deals leave anti-evasion efforts uncertain

With Switzerland and Germany reaching agreement on a deal to prevent tax evasion through Swiss bank accounts from influencing Germans’ investment decisions, and a Swiss deal with the UK announced on August 24, Matthew Gilleard looks at where this leaves international efforts to clamp down on tax evasion.

Matthew Gilleard, August 31 2011

Indonesia: The role of Indonesia’s Tax Court

Suryohadi Based on the self-assessment system, the Directorate General of Taxes (DGT) has the right to audit the returns as a control mechanism. The main objective of a tax audit is to ensure that taxpayers have dutifully fulfilled its tax obligations in accordance with the tax laws, and hopefully it will also raise tax revenue.

August 31 2011

Cyprus: The Cypriot perspective on CCCTB

Anna Zafirova The proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) released on March 16 2011 has fueled the debate on its rationale and potential effects on national economies and cross-border businesses.

August 31 2011

Hong Kong Revenue appeals Li & Fung decision

The Hong Kong tax authorities will contest the Court of First Instance’s decision in the Li & Fung case.

August 31 2011

Romania: Practical issues with permanent establishments

Alex Milcev The Romanian tax regulations on permanent establishment (PE) aspects are broadly similar to the PE definition given by the OECD Model Tax Convention, based on which the majority of the double tax treaties concluded by Romania are structured. Such treaties have precedence over the Romanian tax legislation provided that a valid certificate of fiscal residency of the non-resident is available.

August 31 2011

Chile: Provisional withholding in transactions between foreign taxpayers earning Chilean sourced income

Germán Campos Rodrigo Winter Pursuant to Chilean income tax law, as general rule taxpayers remitting abroad, withdrawing, distributing or paying amounts which are subject to withholding tax in accordance with Chilean law must provisionally withhold a certain amount depending on the characterisation of the income.

August 31 2011

Finland: Tax policy of the new Finnish government

Janne Juusela On June 17 2011 the new Finnish government reached agreement on the new Government Programme. The programme includes the definition of the government's fiscal policy for the commenced term of four years. The fiscal policy pursues to secure the financing of welfare services and to balance the national economy while strengthening the economic growth and employment.

August 31 2011

FYR Macedonia: Transfer pricing and thin capitalisation

Elena Kostovska FYR Macedonia is one country where the concepts of transfer pricing and thin capitalisation are not as developed as in the tax legislations of other countries. However, there are certain rules and procedures stipulated in the Profit Tax Law that may have impact on transactions involving foreign investors.

August 31 2011

France: New guidance elements on abuse of law principle

Helene Rives Fabien Cotte The line between efficient tax management and tax avoidance is often extremely fine. When devising an efficient tax strategy, businesses must always be wary of staying on the acceptable side of this threshold. A recent decision by the French Conseil d'État (CE – the Supreme Court) provides much-needed clarification in this area.

August 31 2011

Canada: Supreme Court of Canada to have final word on residence of trusts

Bryan Bailey Ilan Braude On June 23 2011 the Supreme Court of Canada granted the taxpayer's application for leave to appeal the decision of the Federal Court of Appeal (FCA) in St Michael Trust Corp v The Queen (commonly referred to as Garron). The FCA upheld the decision of the Tax Court of Canada that certain offshore trusts were taxable in Canada on the basis that they were resident in Canada for Canadian tax purposes.

August 31 2011

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