ITR Search | International Tax Review

New trends emerge in Russian court practice on acquisition deals

Galina Naumenko Olesya Ivanik Historically, foreign investors acquiring shares in Russian companies mainly considered tax risks of the purchased legal entities based upon tax due diligence of the target Russian companies. Tax risks of the seller, including those arising from pre-transaction restructuring, have usually been treated as risks which do not affect the new investor. Recent court decisions, however, indicate that there are additional risks to consider when making investments in Russia.

September 30 2007

Taxation of companies' foreign profits

The Treasury issued a consultation document in June 2007 inviting comment on the proposed reform of the UK's controlled foreign company (CFC) regime. The paper proposes a new income-based system for controlled companies (CC).

September 30 2007

Bentham to lead West of England PwC tax practice

Tracey Bentham Tracey Bentham has been appointed partner in charge of the West region tax practice at PricewaterhouseCoopers (PwC). She joined the firm in 1982 and has been a tax partner since 1999. In her new role Bentham will be responsible for a practice of more than 100 tax specialists, covering the entire spectrum of tax advice from international tax structuring to share schemes and reward.

September 30 2007

Fowler makes the board

Jamie Fowler, a Grant Thornton US tax partner, has been promoted to the firm's new national managing partner - national tax process group position. As a result of this position, she will join the firm's national leadership and national tax leadership teams.

September 30 2007

Tobin quits New York for London

Jim Tobin Ernst & Young has announced that Jim Tobin, the firm's global international tax services (ITS) leader, has shifted his primary base to the UK. He will continue his responsibilities as ITS leader and will also become a key member of the UK tax leadership team.

September 30 2007

Congress reviews international tax legislation

Edward Tanenbaum Two significant pieces of international tax legislation are working their way through Congress this autumn.

September 30 2007

Rarity of court cases on cross-border tax issues

Peter Dachs The Supreme Court of Appeal has made a rare judgment on a permanent establishment issue. The appellant in the case qualified as a resident of South Africa and was a partner in a law firm in Lesotho.

September 30 2007

New Japan-Australia tax treaty is agreed

Akio Takisaki The governments of Japan and Australia confirmed that they had reached a basic agreement on a new tax treaty between Japan and Australia on August 3 2007. The details have not yet been announced. The new treaty will come into effect after its finalisation by the two governments and its approval by their respective parliaments, which is assumed to take some time.

September 30 2007

Tax audits turn nasty

Tax audits can be daunting and scary. When a company is facing that process in a new country for the first time, it can also be confusing. Catherine Snowdon learns about the investigations carried out in various countries and hears how best to deal with the tax authorities.

September 30 2007

India: Business restructuring and its transfer pricing implications

Although tax is no longer necessarily the primary driver for restructuring, companies can nevertheless optimise taxes by planning the restructuring appropriately, reveal Indraneel Roy Choudhury and Rakesh Mishra of PricewaterhouseCoopers

September 30 2007

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