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  • Mason Hayes + Curran has hired another partner for its tax practice in Dublin. Petrina Smyth, formerly head of tax for Maples & Calder in the same city, will join the firm on November 1. She is a specialist in asset finance, collective investment undertakings and structuring M&A transactions. John Gulliver joined the firm as head of tax in January.
  • Pravin Gordhan, South Africa's finance minister, announced the South African Revenue Service (SARS)'s intention to launch a voluntary disclosure programme (VDP) in his budget speech earlier this year. The VDP will be instituted, as part of the Taxation Laws Second Amendment Bill, 2010 (Bill), from November 1 2010 to October 31 2011.
  • Slobodan Mihajlovic The long-awaited double taxation treaty between Serbia and Austria was signed on May 7 2010. The treaty has been ratified by Serbia and published in the official Gazette on July 28 2010 will enter into force upon ratification of Austria and shall be effective as of January 1 of the calendar year following the year of entry into force of the agreement. The treaty is very important as Austria is one of the biggest investors in Serbia.
  • David Cuéllar Rachel Costello The UK tax authority, HM Revenue & Customs, recently issued a draft order on the protocol which amends the 1994 tax treaty with Mexico, as well as a memorandum that explains the draft statutory instrument for the protocol.
  • Takeo Mizutani Michael Shikuma On June 11 2010, the Tokyo Stock Exchange (TSE) released a copy of an informal ruling request dated November 5 2009 which it submitted to the Japanese tax authorities (NTA) requesting confirmation of the tax treatment of foreign investors trading on the TSE through a co-location arrangement. Co-location is a service that minimises the latency between a trading participant's devices, such as automated order placement servers, by allowing trading participants to install their devices at the data centre where TSE places its trading engines and market information systems.
  • Sead Dado Salkovic Many companies strive to merge themselves in one powerful company that should create a strong competitor within the business market and gain increased market share. The desire for the merger of two legal institutions could be directly correlated with the economic crisis as it eliminates the actual problems of insolvency and minimises the operational risks.
  • Ingrid Anne Kinden During the last year Norwegian tax authorities have started negotiations with Singapore for a tax treaty between the two countries.
  • Keith O'Donnell Samantha Nonnenkamp The fund tax regime has been improved for master feeder funds and foreign funds managed in Luxembourg. Both fund types are expected to grow after UCITS IV.
  • Gerry Thornton Ireland has reduced the tax compliance requirements for Irish funds marketed to international investors in a move which underlines the commitment of the Irish authorities to Ireland's status as a leading funds domicile.
  • Orestis Livadas Sophie Stylianou After clarifications provided in December 2009 about the term "directly invested", the Moscow Department of the Russian Federal Tax Service and the Russian Ministry of Finance moved a step forward and provided further explanations concerning the definition of permanent establishment (PE), the treatment of liquidation proceeds and the recharacterised interest (to dividends) for the application of the double tax treaty (DTT) between Cyprus and the Russian Federation. These changes seem to reveal the Russian intention for the application of the DTT in place between Cyprus and Russia especially in the treatment of PE as well as interest payments.