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Income Tax Department appeals decision on captive

Bob Reynolds reports on a case which will have widespread implications for companies

KR Girish and Rohit Jain, of KPMG in South India, review the Supreme Court verdict in Morgan Stanley

John Neighbour runs a team of 80 UK-based transfer pricing specialists for KPMG. He was formerly head of transfer pricing at the OECD

Freedom of establishment – Taxation of companies – Exchange loss suffered by companies established in one member state on repatriation of start-up capital granted to permanent establishment in another member state.

Articles 56 EC and 58 EC; Free movement of capital; National tax legislation providing for exemption of shareholdings from corporation tax; Taxation of dividends; Withholding tax; Exemption from withholding tax; Application to companies receiving dividends with a seat or permanent establishment in the Member State granting the exemption and whose shareholdings benefit from exemption from corporation tax; Refusal to apply the exemption from withholding tax to dividends distributed to a recipient company not having a seat or a permanent establishment in that Member State;

Articles 56 EC and 58 EC – Free movement of capital – National tax legislation providing for exemption of shareholdings from corporation tax – Taxation of dividends – Withholding tax – Exemption from withholding tax – Application to companies receiving dividends with a seat or permanent establishment in the member state granting the exemption and whose shareholdings benefit from exemption from corporation tax – Refusal to apply the exemption from withholding tax to dividends distributed to a recipient company not having a seat or a permanent establishment in that member state.

Indirect taxes – Raising of capital – Transfer of the seat of a company – Abolition of the capital duty charged to a company.

Scott Johnson and Jamiel Poindexter have become partners of Proskauer Rose in the firm's Boston office. They are both members of Proskauer's private investment funds group.

The US tax authority will increase its outreach to international taxpayers, as well as taxpayers in US territories such as Guam, Puerto Rico and the US Virgin Islands