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Amendments to the Corporate Income Tax Act

Jordi Domínguez The Spanish parliament has approved an amendment to the provisions governing the accounting principles under which Spanish companies elaborate their annual accounts (not yet published in the Spanish official Gazette). The amendment follows the provisions of article 5 of regulation (EC) no. 1606/2002, of the European Parliament and of the Council, on the application of international accounting standards.

June 30 2007

Tax treatment on cross-border software transactions

Lily Hsu The Ministry of Finance on April 9 2007, issued a tax ruling Tai-Tsai-Shui no.

June 30 2007

IRS expands restrictions on Killer B transactions

Edward Tanenbaum Notice 2007-48, expanding on Notice 2006-85, shuts down the variation of the Killer B transaction in which a controlled foreign corporation (CFC) acquires stock in its parent from the parent's shareholders for use in a triangular reorganisation. Like the classic Killer B transaction in which the CFC paid the parent for its stock, this transaction is also apparently seen as a way for the CFC to repatriate foreign earnings without drawing US corporate level income tax.

June 30 2007

Clarifications to the tax law

Ilarion Lemetyuynen Marina Malakha The Russian Ministry of Finance recently issued two interesting letters, indicating the tax authorities' view of the following areas of application of the tax law:

June 30 2007

How US services rules affect non-US taxpayers

By Gianni De Robertis (Italy), Sean Foley (US), Jaap Reyneveld (The Netherlands), Sergio Schuindt (Brazil) and Tomoko Wada (Japan)

June 30 2007

OECD's authorised approach presents challenges

By Jan Martens (France), John Neighbour (UK), Damian Preshaw (Australia) and Robin Saunders (UK)

June 30 2007

Introduction

By Clark Chandler (US), Steve Fortier (US), Steve Kadenacy (US), Masanori Kawanobe (Japan) and Dave Rutges (The Netherlands)

June 30 2007

Traps for the unwary in new income tax law

Alan Granwell, partner in DLA Piper's Washington DC office, and Qinghua Xu, China group director for the continental Western European area, Ernst & Young, examine the new Chinese Enterprise Income Tax Law

June 30 2007

New standards for private equity

Chris Wales examines the true meaning the recent UK private equity taxation debate

June 30 2007

New restrictions on input VAT deductions on passenger cars breaches EU legislation

Rafal Mikulski Polish restrictions on input VAT on passenger cars violate the European Union's sixth directive. The Administrative Court (First Instance) in Wroclaw, Poland, on April 4 2007 has issued a precedential verdict in which it has decided that Polish restrictions on the input VAT deductions on purchase, import and lease of passenger cars violates the Sixth Directive standstill regulations.

June 30 2007

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