ITR Search | International Tax Review

CIDE no longer due on imports of software

Nélio Weiss Philippe Jeffrey On February 27 2007, President Lula approved law 11.452 that eliminates the levy of the 10% Contribution for Intervention in the Economic Domain (CIDE). Previously paid by legal entities which hold a licence to use or re-sell software.

March 31 2007

German finance ministry answers reform critics

Germany's parliament will decide on reform this summer It is not often that a corporate tax cut causes outrage from business. But Germany's proposal for a rate reduction of almost nine percentage points has attracted as much criticism as praise.

March 31 2007

Domestic reverse hybrid rules apply substance over form principles

Edward Tanenbaum Overview A legal memorandum issued by the IRS (ILM 200645018) has held that the domestic reverse hybrid (DRH) rules apply to deemed payments, and not just actual payments, under a substance over form doctrine. As such, deemed interest payments were treated as constructive dividends.

March 31 2007

Four new double tax treaties entered into by Poland

Monika Dziedzic Poland has signed treaties with Georgia, Iran, New Zealand and the UK. The new agreement with the UK replaces the 1976 treaty.

March 31 2007

The race is on

Countries are using tax to compete fiercely for investment. Switzerland should make sure it is not left behind, says Andrin Waldburger of PricewaterhouseCoopers

March 31 2007

Editorial

A layer of the tax system exists out there that tax directors cannot ignore. Regional taxes are not common to every country, but where they do appear executives can either be lucky or unlucky. They could have a pain-free ride tor they could get so bogged down in complexity that pulling teeth without anaesthesia might seem like an easier choice.

March 31 2007

Finance Bill 2007 - the key amendments

Rajendra Nayak Ganesh Pai The Union Budget 2007 came in the backdrop of searing growth of over 9% for the second consecutive year and a raft of positive economic indicators, the only negative being the high inflation rate. Promisingly, the Budget includes significant allowances for agriculture and the rural economy.

March 31 2007

Central America update

Antonio Ruiz Costa Rica New provisions referred to as the Voluntary Complementary Pensions Fund (VCPF) entered in force as of February 15 2007. Said provisions allow the deduction from individual income tax liabilities, of the monthly VCPF contribution made by employees.

March 31 2007

Creditability questions

Kumar Girish from BSR & Co and Caren Shein from KPMG look at India's dividend distribution and the IRC

March 31 2007

Legislature approves new Income Tax and Value Added Tax laws

As referred to in the March update in the International Tax Review, the Value Added Tax law published in Official Gazette No. 38.632 of February 26 2007 has now been approved. Also accepted was the Income Tax law published in Official Gazette No. 38.628 of February 16 2007. Both regulations will be in force for fiscal years beginning after their issuance dates (March and beyond). The thin capitalization debt-to-equity ratio included in the Income Tax Law was set at 1:1.

March 31 2007

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