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Akio Takisaki Recently the Tokyo High Court ruled that a US LLC (limited liability company) shall be treated as a foreign corporation for Japanese tax purposes and that its distribution to a Japanese taxpayer shall be taxed as dividend income in Japan.

German banks should put their strategy into place now if they want to be ready for the flat tax. Hans-Ulrich Lauermann and Benjamin Laves of PricewaterhouseCoopers explain why

David Forst and Barton Bassett of Fenwick & West discuss new income tax rules and a treaty that will affect international deals

Top-down and bottom-up represent the two types of valuation logic that exist for the quantification of arm's-length royalties for know-how and knowledge in intercompany transactions, explain Alexander Vögele and Wolf Witt of NERA Economic Consulting

After a slow start, the pace of treaty negotiations has picked up, report Carlos Iannucci of Deloitte in Argentina, Cristina Arantes Berry of Deloitte in Brazil and Anthony Cook of Deloitte in Chile

Gagnon Jean On November 13, 2007, the Department of Finance tabled a Notice of Ways and means motion to implement proposed amendments to the Income Tax Act partly in response to fiscal policies previously anno-unced. The amendments include the following measures:

Nélio B. Weiss Philippe Jeffrey A Brazilian court of first instance from the State of Espírito Santo recently issued an important decision in connection with the non-application of withholding income tax on remittance for services to a beneficiary located in a tax treaty country. The court ruled out that remittance for technical service (not involving a transfer of technology or know-how) to a resident of Finland could not be subject to the 15% Brazilian withholding income tax due to the application of the article 7 (business profits) included in the Brazil-Finland tax treaty.

Andrés Edelstein Ignacio Rodríguez Argentina non-residents are subject to income tax exclusively on their Argentine-source income. Pursuant to this rule, the non-resident pays tax through a 35% withholding tax levied on a deemed net income equivalent to a percentage of the gross payment received. Unless provided otherwise in the income tax law, 90% of the gross revenue derived by the non-resident from Argentine source is deemed taxable net income, which gives rise to an effective 31.5% withholding tax.

Tax executives and advisers came from all over Asia to attend the second annual International Tax Review Asia Tax Awards in Hong Kong in November

Bob Reynolds talks to Dave Hartnett, acting chairman of HMRC, about openness and dialogue with international businesses