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  • Zeki Gündüz As it is known, transfer pricing legislation in Turkey has been one of the most focused tax legislations since its first enactment in 2007. During the past three years, unsurprisingly there have been long debates about various topics, which had/still also discussed by most of the European countries that have enacted transfer pricing long before.
  • In a legislative proposal announced on October 5 2010 the Norwegian government proposed changes to the VAT Act making suppliers not established in Norway obligated to charge VAT when supplying electronic services to Norwegian consumers (B2C). Today, only suppliers established in Norway must charge VAT when such services are supplied to Norwegian consumers. The proposal will lead to equal terms for suppliers established within and outside Norway respectively, supplying electronic services to Norwegian consumers.
  • Slobodan Mihajlovic International investors have two options when deciding how to finance their investments in subsidiary companies. These options regard to a decision on whether to introduce funds by way of capital injection or through debt. Financing a subsidiary through debt is a more tax wise solution as interest is tax deductible (decreasing corporate tax) therefore the tax leakage is minimised, whereas dividends will be non-deductible distribution of profits. Thin capitalisation is when there is an excessive ratio of debt to equity such as when the capital of the company is comprised of greater debt than equity. This practice creates a high risk due to the fact that the said debt has to be repaid to the creditors even though the capital reserves are not enough for such repayment.
  • Sead Dado Salkovic Many foreign companies are indirectly present in Montenegrin markets by using various services of resident agent/brokerage companies. Over the past couple of years Montenegro has become an alluring investment destination due to ease of doing business in different areas. Certainly the most attractive sectors are the real-estate, Internet and services concerning tourism.
  • Elena Kostovska For the second time in six months, the FYR Macedonian VAT legislation has been revised. Whereas the last revisions (applicable from 2010) touched on VAT registration deadlines, submissions statements, and changes to the transfer of assets and real estate sales, amendments adopted in late July 2010 mostly concern VAT registration threshold, penalties and new reports submitted along with the tax returns.
  • Loïc Le Claire Richard Juan The 2011 French Finance Bill preserves the attractiveness of the French IP/IT incentives. This includes the R&D tax credit and the reduced taxation of patents. Adjustments to the existing regimes, in force as from January 1 2011 (except the immediate refund, since 2010), include the following:
  • Simeon Grigorov Considering a company's activity from a tax perspective, one of the most essential issues is the scope of application of any allowable deductions. From a Bulgarian prospective, expenses incurred wholly and exclusively for the production of income are treated as deductible expenditure. It is widely used by companies to include the interest payments as part of their expenditures. The question is, however, whether or not, or how much of such interest payments are deductible or not.
  • Alke Fiebig On October 29 2010, the Bundestag passed the Annual Tax Bill 2010 (for 2011) and forwarded it to the Bundesrat for final approval. One of the main features is a change to the CFC rules to counter a perceived abuse. The principle behind the CFC rules is to attribute passive income to the German parent if retained by a foreign subsidiary after effective taxation of less than 25%.
  • GST, Canada, property, credit card agreement
  • The UK's top banks have signed up to the government's code on banking taxation.