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  • Slobodan Mihajlovic Sead Dado Salkovic Aiming to improve tax legislation, the government of Republika Srpska (RS) is adopting a package of tax solutions needed for more "rational and competitive" tax system in this Bosnian entity.
  • Gary Thomas As part of its 2011 tax reforms which were belatedly passed in late June, Japan has adopted the most appropriate method rule for selecting a transfer pricing method. According to the new rule, the arm's-length price is the amount which is computed in accordance with the most appropriate method, taking into account the contents of the transaction, the functions performed by the parties and other circumstances. This change will go into effect for tax years commencing on or after October 1 2011.
  • Paul Chambers Samantha Nonnenkamp The Luxembourg government recently adopted a draft law that amends, as of January 1 2012, the regime applicable to SPFs (private wealth management companies), as defined by the law of May 11 2007 (SPF Law). SPFs are investment vehicles dedicated to private investors which benefit, under certain conditions, from an exemption from corporate income tax (CIT) and municipal business tax (MBT) on profits and capital gains as well as from net wealth tax (NWT). In the following developments, we explain why the SPF regime had to be amended and why this amendment will make SPFs even more attractive than before.
  • Simeon Grigorov More and more Greek and Romanian companies are registering in Bulgaria, one of the three countries with the lowest corporate taxes in the EU. According to the NRA (National Revenue Agency) the number of companies with Greek capital, that declared corporate income tax in Bulgaria for 2010 is 2074. This is 183% more than in 2006.
  • Ian Farmer The much anticipated exposure draft (ED) legislation for the proposed minerals resource rent tax (MRRT) was released on June 10 2011, accompanied by detailed explanatory material. This is a significant step towards the implementation of the proposed MRRT as announced by the government on July 2 2010.
  • Gerry Thornton Barry McGettrick Ireland signed a double tax treaty with Armenia on July 14 2011 bringing to 63 the number of tax treaties which Ireland has signed. The treaty substantially follows the OECD model convention in dealing with issues such as residence, permanent establishment and exchange of information.
  • Peter Dachs The annual amendments to South Africa's tax legislation are mainly aimed at refining, tightening and clarifying the provisions of the relevant legislation. However, in 2010 and 2011, we have seen significant changes which have a fundamental impact on both resident and non-resident taxpayers. Some of these changes are already in force whilst others will come into effect in 2012 and 2013.
  • Taxpayers in India can avoid long disputes if they pay for the best lawyers rather than “watching the pennies”, says a top tax director.
  • The Mumbai Tribunal has ruled that a software payment is not a royalty under the India-Israel double tax treaty.
  • Court says Canadian tax will not be affected by how a transaction is characterised for foreign tax purposes.