ITR Search | International Tax Review

Treaty shopping - the next chapter

Bryan Bailey Jeffrey Shafer On June 13 2007, a three-judge panel of the Federal Court of Appeal unanimously upheld the tax court of Canada's August 2006 decision in MIL (Investments) S.A.V.R. This was the first treaty-shopping case litigated in Canada.

August 31 2007

Czech government wins corporate tax cut

Prague parliament Corporate taxes in the Czech Republic will be cut to 21%. This is a key result of a vote on a wider package of tax reforms which was passed by the Czech parliament.

August 31 2007

Doggett bill faces uncertain future

Representative Lloyd Doggett wants to alter significantly the way that US withholding taxes are computed on deductible payments made to foreign persons. Mike Patton, principal at Ernst & Young Los Angeles, explains why Doggett will not succeed

August 31 2007

New Irish tax president selected

Joan O'Connor has been selected as the new president of the Irish Taxation Institute (ITI). An international tax partner with Deloitte, she has 25 years' experience in the taxation profession, advising Irish domestic public and private companies and inbound multinational companies.

August 31 2007

Peru

Claudia González-Béndiksen and Paola Gutiérrez expect the tax authorities in Peru to increase their focus on transfer pricing issues soon

August 31 2007

Changes to secondary taxation

Peter Dachs It is proposed that from some time next year secondary tax on companies will be changed to a tax on the shareholder receiving the dividend (as opposed to its current form where it is imposed on the company declaring the dividend) and levied at a rate of 10%.

August 31 2007

Inheritance and gift tax repealed by Constitutional Court

Clemens Hasenauer Johannes Prinz In decisions dated March 7 2007 and June 15 2007, the Austrian Constitutional Court (Verfassun gsgerichtshof) repealed the inheritance and gift tax. The repeal will come into effect as of July 31 2008 unless the Austrian legislator amends the tax before this date.

August 31 2007

2008 tax reform targets business restructuring

Jobst Wilmanns Martin Schmitt Now that the Bundesrat has approved the Corporate Tax Reform Act 2008, attention has turned to the practical implications. Of prime importance is the new definition of arm's length transfer prices, particularly in respect of business restructuring.

August 31 2007

Interpretation of the China - Hong Kong double tax arrangement

Stephen Nelson Our last article addressed processing and assembly arrangements and permanent establishment issues under the recent PRC State Administration of Taxation (SAT) notice (Guoshui (2007) 403) on the China-Hong Kong double tax arrangement (DTA). We now continue our discussion of issues arising from the notice, focusing on the interpretation of capital gains exemption.

August 31 2007

Tax treaty signed between Costa Rica and Spain

Antonio Ruiz On February 3 2004, the governments of Costa Rica and Spain signed a treaty for the avoidance of double taxation and prevention of fiscal evasion, on income and equity taxes (the treaty). This bill is under scrutiny by the Costa Rican Congress and it is expected to be approved in the following months.

August 31 2007

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