ITR Search | International Tax Review

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

Montenegro: VAT on sports activities

Sead Dado Salkovic Montenegro is showing great interests in all aspects of sport. Many professional athletes perform their activities according to the regulations specified by the general act of sporting organisation. The question is, what about the VAT subsequences of these services?

August 31 2011

IRS announces phased implementation of FATCA

Thomas Humphreys, Remmelt Reigersman and Jared Goldberger of Morrison & Foerster run through the latest developments for FATCA in the US and explain that foreign financial institutions and withholding agents should benefit from additional time to comply with the rules.

August 31 2011

Mexico: Mexican Flat Tax after three years of implementation

David Cuéllar Claudia Solano The Flat Tax Law was published on October 1 2007, entering into force as from January 1 2008. As part of the transitory provisions of the Flat Tax Law, article 19 establishes that the Mexican tax authorities shall conduct a study showing a comprehensive diagnostic regarding the convenience of repealing certain chapters of the Mexican Income Tax Law (regarding the tax regime applicable to the entities and individuals), to be regulated solely by the Flat Tax Law.

August 31 2011

SPECIAL FEATURE: How related party status is influencing football club deals

Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA.

August 30 2011

How to price embedded intangibles in the US

An embedded intangible is an element of another category of transaction, according to Rob Plunkett of Deloitte’s Washington office.

August 30 2011

Search results for