ITR Search | International Tax Review

Extension of holding regime to EU-incorporated entities

Tiago Cassiano Neves Law 10/2008 of March 10 extends the tax regime applicable to Portuguese incorporated holding companies (SGPS) to EU-incorporated entities that move their seat or place of effective management into Portugal.

March 31 2009

IRS modifies the application of section 367 to certain cross-border stock transfers

Sean Foley On February 10 2009, the Treasury department and IRS released temporary regulations (T.D. 9444) modifying the section 367 regulations by applying sections 367(a) and (b) to certain international section 304(a)(1) transactions, commonly referred to as cross-chain stock sales. The temporary regulations apply to transfers or distributions occurring on or after February 11 2009.

March 31 2009

Tax initiatives to boost employment

Thomas Pippos Since writing about a number of tax measures the government was taking to improve cash flows for businesses in the current economic climate, the prime minister also hosted an employment summit at the end of February attended by business leaders from around the country.

March 31 2009

Asia Pacific

Comparisons within and across the ASPAC region. By Steven Tseng, Yasuhiko Otani, and Hiroyuki Takahashi, all from KPMG in China, Sherry Chang, and Karl Chan, both from KPMG in Taiwan

March 31 2009

Tax rules have advantages for employees

If companies think ahead there are tax benefits in moving employees to Switzerland, believes Peter Vogt of Tax Partner

March 31 2009

Diane Hay interview: Better understanding between business and governments is needed

Diane Hay left HM Revenue & Customs in mid-December 2008 after more than 30 in the UK years working in high profile tax and business roles, including 15 years in international tax. As former deputy director, CT & VAT and head of the Transfer Pricing Group, Hay tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority, offers taxpayers an insight into how transfer pricing cases are selected and talks about the future of transfer pricing

March 31 2009

India

Ripple effects from around the world come to India. By Rakesh Alshi, V.Subramaniam and Devesh Doshi, Deloitte Haskins & Sells, India

March 31 2009

Germany

Transfer pricing controversy and other developments. By Oliver Wehnert, Ernst & Young, Düsseldorf

March 31 2009

Denmark makes substantial adjustments

The Danish tax authorities made transfer pricing adjustments of more than $1 billion in 2008, almost three times as much as the previous year, even though they finalised fewer cases

March 31 2009

Tax authorities seek to clarify the treatment of intercompany loans

The Israeli tax authorities have proposed the clarification of the tax treatment of intercompany loans

March 31 2009

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