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Deals: Warner Chilcott signs five year APA deal with IRS

Ong Sim Ho, a well known tax litigator in Singapore, closed his tax boutique of the same name and moved to Drew & Napier on March 3. Ong, who is a former official of the Inland Revenue Authority of Singapore, had run his own firm since December 2001.

Union government signs with Luxembourg and completes negotiation with Cyprus

Swallows Holding has become a talking point among US tax professionals for what it says about timely returns. Jim Fuller, of Fenwick & West, explains why the appeal court reversed the US Tax Court's initial finding

By Bob Reynolds

The adoption by EU economy and finance ministers of the VAT Package on February 12 means VAT on services will accrue to the country of consumption, an electronic system for claiming refunds will begin operating and particular arrangements for telecommunications, broadcasting and electronic services will be set up.

By Bob Reynolds

Bob van der Made On December 10 and 11 2007, a joint meeting of the European Commission with business representatives (including the European Business Initiative on Taxation and Business Europe) and academics took place in Brussels, with the EU member states attending as observers. The purpose of the meeting was to give participants an update of the Common Consolidated Corporate Tax Base (CCCTB) working group's work to date, focusing especially on a number of discussion documents on the possible outline of a CCCTB. The main points coming out of these discussion documents are summarised below.

Rajendra Nayak Ganesh Pai The Kolkata Income Tax Appellate Tribunal (ITAT) in the case of Van Oord Atlanta B.V. v Asstt Director of IT (2007) 112 TTJ (Kol) 229 recently examined the question of existence of a permanent establishment (PE) in India. Van Oord Atlanta BV (BV co) was a company incorporated in the Netherlands. BV co had undertaken a sub-contract for dredging to be executed in India. As a result of this sub-contract, BV co had a project office and a dredger in India for a period of 153 days. Once the project was completed, the dredger sailed out of India, but BV co maintained a bank account and books of accounts in India, even after this period. BV co claimed that maintenance of a bank account and books of accounts could not be termed as "business carried on" from a "fixed place of business". The issue before the ITAT was, whether the mere activity of maintenance of a bank account and books of accounts, could create a PE for the BV co in India as per article 5 of the India - Netherlands double taxation avoidance agreement (DTAA). BV co was a resident of the Netherlands within the meaning of article 4 of the treaty and was eligible for the DTAA benefits.

Due to a query regarding the application of the double tax convention between Chile and Spain (DTC), the Chilean tax authority (SII) has clarified some issues relating to the application of article 7 in case of the provision of services by a foreign company.