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  • aus-ffc150.jpg
    Australian commissioner will not appeal SNF comparables ruling
    The Australian Tax Office (ATO) will not appeal the Full Federal Court decision on comparables, which ruled in favour of the taxpayer, SNF, as the 28-day leave for the Commissioner to seek appeal has now passed.
    June 30 2011
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    Capacity building is key to transfer pricing development
    Countries losing money from multinationals’ transfer pricing are, more often than not, lacking the ability to implement the arm’s-length principle effectively, one of Africa’s leading tax officials has said .
    June 30 2011
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    Austria: Austria shows its colours as a holding company location
    Niklas Schmidt and Eva Stadler of Wolf Theiss describe the features of the tax regime in Austria that make it attractive to holding companies. For example, Austria does not have controlled foreign company or thin capitalisation rules, and its participation exemption system is favourable to international companies
    June 29 2011
  • Editorial
    Jurisdictions around the world are cooperating more and more on tax issues. The EU, the OECD and the UN already have programmes in place, though not all looking at the same topics. Governments feel that because of the amount of cross-border trade that goes on, it is vital that they can obtain the right information about the tax affairs of companies.
    June 29 2011
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    Sweden: Swedish position on capital attribution will lead to double taxation
    Sweden does not allow the attribution of capital to permanent establishments. It should change its position to help companies avoid double taxation, explains David Perrone of KPMG
    June 29 2011
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    Japan: Article 63 exemption and investment manager licensing
    Koichiro Ohashi, Koji Yamamoto and Yoshiyuki Omori of White & Case describe fund distribution in Japan and analyse the article 63 exemption from business registration requirements which is increasingly being used by offshore managers as a resource-saving technique to distribute securities in Japan, and recent amendments to the securities law in relation to fund distribution to professional investors.
    June 29 2011
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    Ireland: Tax changes ensure a bright future for finance in Ireland
    As Ireland shows some signs of economic recovery, the government’s commitment to financial services, seen in some key changes to the tax system recently, augurs well for the sector, believe Conor Hurley and Alan Heuston of Arthur Cox
    June 29 2011
  • German energy providers take legal action against nuclear fuel tax
    RWE, the German public utility company, filed a suit on June 21 in a Munich tax court against the German government objecting to the country’s nuclear fuel levy.
    Matthew Gilleard, June 29 2011
  • gidwani.jpg
    India: India sustains capital markets development
    Newer products and newer technology being used by the players in Indian capital markets have significant tax implications which investors must be aware of, believes Sunil Gidwani of PwC
    June 29 2011
  • UK launches CFC consultation
    The Treasury today opened a consultation on rules for controlled foreign companies (CFCs) as part of the government’s aim to improve the UK’s competitiveness without harming the tax base.
    June 29 2011
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