ITR Search | International Tax Review

Tax treaty between Mexico and the Slovak Republic

Roberto del Toro Salvador Esquivel The tax treaty between Mexico and the Slovak Republic was signed on May 13 2006 and approved on July 13 2007. The treaty will enter into force 60 days after each country has notified the other of the completion of its ratification. All treaty provisions will apply as from January 1 of the calendar year following its entry in force.

August 31 2007

Grant Thornton recruits new transfer pricing leader

Grant Thornton in America has appointed a new head of transfer pricing. David Bowen has joined from the Internal Revenue Service where he worked in the associate chief counsel's office.

August 31 2007

Uruguay

The tax authorities need more rules to help them implement international transfer pricing standards, believe Rubén Hernández and Gabriela Villavicencio

August 31 2007

E&Y tax leader joins Moss Adams

America's 12th largest accountant Moss Adams has recruited Michael Ferguson as a partner in its international services group. He was formerly international tax services leader for Ernst & Young in Seattle and Portland.

August 31 2007

NTS announces tax audit directive for 2007

Henry An The National Tax Service (NTS) announced its tax audit directive for 2007 in July. The NTS indicated that the percentage of corporate taxpayers selected for tax audit would again be reduced, but that those selected for tax audit would be subject to more intense scrutiny. Specifically, the percentage of corporate taxpayers selected for tax audit would decrease from 0.9% in 2006 to 0.8% in 2007, which represents approximately 2,800 companies.

August 31 2007

New proposed CFC legislation

Carl Pihlgren The Swedish ministry of finance has recently announced a proposal of changes to the CFC legislation due to the Cadbury Schweppes case (C-196/04). According to the case CFC legis-lation can be regarded as compatible with EC law if it is restricted in its application to wholly artificial arrangements. The proposal gives shareholders in lower taxed companies the possi-bility to avoid CFC taxation if certain requirements are met.

August 31 2007

Blacklist for application of participation exemption for dividends

Ilarion Lemetyuynen Marina Malakha In the June 2007 issue of International Tax Review we wrote about the new Russian holding regime, which becomes effective from January 1 2008. One of the conditions for the application of this holding regime is that a foreign company, which distributes dividends to a Russian parent, is not from a black-listed jurisdiction.

August 31 2007

New rules on advance tax rulings

Malgorzata Sobonska The amendments to the Polish tax code (Tax Ordinance) which came into force from July 1 2007 caused quite important changes in the process of obtaining advance tax rulings. Until June 30 2007 rulings were issued by the local tax offices and if the taxpayer was not satisfied with the rulings, they were able to appeal the rulings to the tax chamber.

August 31 2007

Supreme Court clarifies tax position of foreign companies with outsourced services in India

Rajendra Nayak Ganesh Pai The Supreme Court (SC) of India in the case of DIT v Morgan Stanley & Co (292 ITR 416) recently examined certain issues relating to taxation of a foreign company in India. Morgan Stanley (MS) is an investment bank incorporated in the US and provides financial advisory services. It has a subsidiary in India, Morgan Stanley Advantage Services Private (MSAS) which provides support to the group's front office functions in their global operations.

August 31 2007

Tax considerations in acquisitions of high-tech companies

Israel's innovative entrepreneurship and pioneering technologies makes it attractive for capital investments. This article is one of a series of articles aimed at discussing the unique features of high-tech companies in Israel and the main tax considerations that should be considered when acquiring such companies.

August 31 2007

Search results for