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  • Moral vs bottom line
    Jeffrey Owens, no less – probably the world's most influential tax official – told delegates at a two-day tax planning conference in Paris last month that tax is "not a moral issue, but a bottom line issue".
    April 30 2011
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    Canada reacts to taxpayer friendly decision
    John Leopardi Emmanuel Sala In March 2011 Finance Canada released legislative proposals to Part XIII of the Canadian Income Tax Act in response to the recent Federal Court of Appeal decision in Lehigh. The proposals target foreign lenders who strip the right to interest from a loan made to a Canadian non-arm's length party and assign such right to an arm's-length foreign party.
    April 30 2011
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    Supreme Court rules on software payments
    Andrés Edelstein Ignacio Rodríguez Argentinean non-residents are subject to income tax exclusively on their Argentine-source income. Pursuant to this rule, a non-resident pays tax through a 35% withholding tax levied on a deemed net income equivalent to a percentage of the gross payment received. Unless provided otherwise in the Income Tax Law, 90% of the gross revenue derived by the non-resident from Argentine source is deemed taxable net income, which gives rise to an effective 31.5% withholding tax.
    April 30 2011
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    Tax Relief
    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com
    April 30 2011
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    VAT at trade fairs
    Hans-Martin Grambeck On February 4 2011, the finance ministry published a decree on the place of supply under the VAT Act of services related to cultural, educational, sporting and other events. Under the new rule these business-to-business (B2B) services are to be taxed from January 1 2011 where the recipient is established. Similar business-to-consumer (B2C) services as well as B2B ticket sales remain taxable where the event actually takes place.
    April 30 2011
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    Cuatrecasas, Gonçalves Pereira makes Picó partner
    Francisco Picó has been appointed partner at Cuatrecasas, Gonçalves Pereira.
    April 30 2011
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    Ryan’s committee unveils alternative US budget
    The Budget Committee of the US House of Representatives has responded to President Obama's budget request in February with its own proposal that would see the corporate tax rate fall from 35% to 25% and eliminate or change tax reliefs for companies.
    April 30 2011
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    Germany seeks cross-border simplification
    Jens-Uwe Hinder and Mathias Schönhaus of Hogan Lovells explain recent changes to German international tax law and their consequences for the taxation of foreign and domestic taxpayers.
    April 30 2011
  • Thin Cap GLO case questions applicability of UK legislation
    Michael Anderson and Kelly Stricklin-Coutinho of Dorsey & Whitney report on the recent decision of the UK Court of Appeal in the Thin Cap GLO and discover that the UK’s thin capitalisation rules may be at odds with the rest of Europe.
    April 30 2011
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    Recovery of VAT on share disposal costs – in France the debate continues
    Stephen Dale Arnaud Moraine We all thought that when the case of AB SKF (Case C-29/08) reached the European Court of Justice (ECJ) at the end of 2009 that there would at last be some clarity about the treatment of the recovery of VAT on the costs related to the disposal of shares; but the clarity long anticipated, was not forthcoming.
    April 30 2011
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