Search results for

Jane Dodd On January 26 2009, HM Revenue & Customs (HMRC) announced certain exclusions with respect to the worldwide debt cap including an exclusion for the UK-REIT regime. The worldwide debt cap operates such that UK interest deductions claimed by large groups will be capped where the UK has more debt than the external debt of the worldwide group.

Carl Pihlgren Sara Bolmstrand On November 24 2008 the Swedish tax agency submitted a proposal to the Swedish government relating to partnerships and the application of the Swedish participation exemption rules. The proposal suggests among other things that the disposal of an interest in a partnership by a Swedish corporate taxpayer could benefit from the application of the Swedish participation exemption. Also, the proposal suggests that a partnership can benefit from the participation exemption rules even if it is not a taxable entity itself.

Manuel Ángel Bouzas In October the Spanish government approved the long-awaited regulations for the development of the new Spanish transfer pricing rules.

Nathalie Urban Daniel Gremaud The Swiss federal government, the Federal Council, recently announced a range of corporate tax reforms designed to increase Switzerland's attractiveness and prospects for growth as a business location. A draft consultation paper on corporate tax reforms will now be prepared by the federal department of finance.

Omissions and a lack of clarity have forced the introduction of a new provision on tax settlements, reveals Fabio Leonardi of Paul Hastings

As the global economic downturn looks set to worsen in 2009, the 10 most admired tax directors in North America tell Catherine Snowdon about the challenges their industries face and the strategies they have put in place to cope

A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month

Taxpayers should be aware of the possible implications of the look-through provisions in the new protocol to the US-Canada treaty, as Elinore Richardson and Stephanie Wong of Borden Ladner Gervais explain

Patricia McDonald Ivan Morales Baker & McKenzie has appointed two new tax partners to the firm's North American offices.

By International Tax Review