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  • A 60-day wage tax exemption for foreign employees working in the Netherlands is welcome news for multinationals, say Dorine Fraai and Roxanna Windzak of Horlings, a member firm of Nexia International
  • Paulo Núncio Tiago Cassiano Neves On June 17 2010 the European Court of Justice (ECJ) issued its judgment in Commission v Portugal (C-105/08), regarding the infringement procedure on the potential discriminatory tax treatment of outbound interest payments to EU/EEA based financial institutions. This case raises the issue of the compatibility of a withholding tax on gross interest paid to non-resident financial institutions, while in a domestic situation taxation is levied on a net basis.
  • Diego Rodríguez The Spanish Corporate Income Tax (CIT) Act contemplates a full exemption for dividends and capital gains obtained by a Spanish company from its foreign subsidiaries. Generally speaking, the conditions to take the exemption are three-fold: A minimum 5% ownership interest must be held uninterruptedly in the subsidiary for at least one year (the minimum ownership interest threshold may be also met if the Spanish company has applied for the ETVE regime for foreign-securities holding companies and the acquisition cost of the ownership interest in the subsidiary is higher than €6 million ($7.2 million); The subsidiary must be subject to an identical or similar tax to the Spanish CIT; And the subsidiary must carry on business activities outside Spain.
  • Bob van der Made The European Commission has missed a self-imposed deadline to produce a formal reaction to former Commissioner Monti's suggestions for re-launching the single market and the role of taxation therein.
  • Monika Dziedzic Many older double tax treaties concluded by Poland are now being renegotiated. The amendments concern mainly treaties concluded in 1970s and 1980s, but there was also a few treaties concluded in 1990s or even in the present decade that are still subject to verification. Recently, Poland has changed treaties with Finland, Norway, Switzerland, and Denmark, but some other significant treaties are also planned to be changed such as the treaty with Belgium, the Czech Republic, the US, Spain, Malaysia, Malta, Cyprus and Canada.
  • India's capital markets have grown rapidly in the last 10 years. It makes it more important than ever that investors should keep up with key regulatory and tax issues in the area, explains Sunil Gidwani of PricewaterhouseCoopers in India
  • Baker & McKenzie adds new partner International law firm Baker & McKenzie has added a transactional tax partner to its New York and Washington offices.
  • Sean Foley Landon McGrew The Internal Revenue Service (IRS) and Treasury department recently announced that they intend to issue new regulations that will classify certain US partnerships as foreign partnerships for purposes of determining the US shareholders of a controlled foreign corporation (CFC) that are required to include in gross income the amounts described in section 951(a), in other words, subpart F income, with respect to the CFC.
  • Osborne plans five year corporate tax reform plan Source: M Holland A banking levy, balanced by a gradual cut in the company tax rate, a five-year plan to reform the corporate tax system and the possibility of a general anti-avoidance rule featured in the first budget of the UK's new coalition government on June 22.
  • The Indian tax authorities are claiming they advised Vodafone to pay tax on its $11.1 billion acquisition of Hutchison a month and a half before the transaction was concluded.