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  • Jordi Domínguez Lorena Colomer Globalisation has meant significant changes in our economy in the last years, and in the mode of operation of the different players as well. One of the more significant changes makes reference to mobility. Not only referred to services or goods delivered or rendered anywhere, but also referred to individuals and entities changing their place of business depending on the circumstances of the global market.
  • By Paolo Giacometti and Raul-Angelo Papotti, Chiomenti Studio Legale
  • Renata Dluska From January 1 2006, Polish business entities which do not operate in special economic zones are entitled to tax relieves/deductions if they acquire qualifying new technologies ;
  • Akio Takisaki On June 28 2007, the Tokyo high court ruled against the Japanese national tax agency's appeal to re-characterise a Tokumei Kumiai (TK) as a Nin-i Kumiai (NK) and treat the TK investor as having a permanent establishment in Japan. The decision is remarkable because it supports the taxpayer who established a tax-savings driven structure.
  • The financial and economic turmoil of the last six months in the US is beginning to influence the campaigns of presidential hopefuls. As International Tax Review's Americas correspondent Catherine Snowdon discovers, despite advice from some of the best economic brains in the US, there are no obvious answers on tax
  • Rajendra Nayak Ganesh Pai In two recent rulings, the Delhi Income-tax Appellate Tribunal (ITAT) has ruled on the question of PE and income attribution to the PE. The rulings are in the case of Rolls Royce Plc vs. DIT which involved the India-UK tax treaty and Galileo International Inc vs. DDIT which involved the India-USA tax treaty. The Rolls Royce ruling relates to the case of a UK company – Rolls Royce (RRPLC) – which was engaged in supplying aero engines to Indian customers. Rolls Royce India Limited (RRIL), a UK subsidiary of RRPLC, had an office in India which was engaged in providing support services to RRPLC.
  • Marco Da Re and Davide Bergami of Ernst & Young in Italy argue that Italy's independent line on permanent establishment could be a source of future problems for business
  • By Ralph Cunningham
  • Emmanuel Picq The French Finance Act for 2008, approved on December 18 2007, includes various measures intended to boost innovation and productivity, including a substantial enhancement of the R&D credit system.
  • Roberto del Toro David Cuellar The Mexican tax authorities published on December 31 2007 a new set of miscellaneous tax regulations including, among others, numerous clarifications on several items (such as definitions, calculations and procedures) related to the recently enacted flat tax.