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  • Competition for investment and fundraising has made governments reexamine how they tax capital markets transactions. So much so, that taxpayers have to work hard to keep up with changing regulations that are making more and more economies suitable for their money. The volume of law in different countries make the easy access to high-quality knowledge and advice essential.
  • Kumar Girish from BSR & Co and Caren Shein from KPMG look at India's dividend distribution and the IRC
  • GlaxoSmithKline has reported a number of unresolved tax issues around the world at the same time as its effective tax rate edged up in 2006.
  • The UK chancellor of the exchequer's gave taxpayers a break with one hand, but snatched it back with the other in the 2007-2008 UK budget.
  • Now is the right time to look at how tax policy is formed, believes Chris Wales
  • 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.
  • By Matthew Desborough-Hurst and Neil Warriner of Herbert Smith
  • 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.
  • Under the treaty regime, business profits earned by a company headquartered in a country that has a treaty with Taiwan are not taxable here unless the company has a Taiwanese permanent establishment (PE). If the company has a PE in Taiwan, the profits earned by the company may be taxed in Taiwan but only those that could be attributed to the PE.
  • Suzanne Boers In 2004, the Netherlands adopted thin capitalisation rules for its national corporate income tax legislation. The Dutch thin cap rules state that interest is not deductible from corporate income if the company's average debt is three times higher than the average equity and this excess is more than €500,000 ($659,000). Furthermore, the amount of interest that is not deductible cannot be higher than the amount of interest paid to related entities, less the amount of interest received from related entities.