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  • Massimo Agostini The Italian Financial Act 2007, enacted December 27 2006, has introduced a new real estate investment vehicle called Società d'investimento immobiliare quotata (SIIQ). It is expected to become the Italian equivalent of, among other things, the US's Real Estate Investment Trusts and the French Societè d'Investissment Immobilier Cotee.
  • Stephen Nelson The long-awaited unified draft enterprise income tax bill was approved by the Standing Committee of the PRC National People's Congress on December 29 2006, and will be submitted to the National People's Congress this March. The tax bill is expected to come into effect from January 1 2008 if approved.
  • Bill increasing foreign tax credit On December 15 2006 the Chilean President sent to Parliament a Bill which aims, among other things, to increase the domestic foreign tax credit for certain inbound income from countries that have not subscribed to double tax conventions with Chile (hereinafter non-treaty countries). The Bill also extends the scope of income taxes that entitle a taxpayer to claim foreign tax credit in the cases of treaty countries; and eliminates formal requirements to be entitled to the aforementioned credit.
  • Nelio Weiss Philippe Jeffrey For a second consecutive year and with the objective to minimise the effect for exporting companies from the appreciation of the local currency in relation to foreign currencies (specifically the US dollar and the Euro) the Brazilian authorities issued on December 29 2006, Ordinance 425 and Normative Instruction 703. The directive amended the Brazilian transfer pricing legislation. As per the latter Ordinance and Normative Instruction, Brazilian exporting companies will be allowed to increase their export revenues for calendar year 2006 (for transfer pricing calculation purposes) using the ratio of 1.29. This exceptional measure will only apply for the fiscal year 2006. As mentioned, a similar measure was also adopted for fiscal year 2005, allowing the Brazilian exporting companies to increase their export revenues using then a ratio of 1.35.
  • Vispi Patel of RSM & Co describes the attitude of the Indian revenue authorities to transfer pricing audits and points out how international taxpayers could mitigate their risk
  • Sec 911 has changed the tax treatment of US expatriates. Edward Gibbons and Leann Balbona of KPMG in the US reveal that housing is only one area where expats and employers may have to rethink their assignment strategies
  • Higher interest deductions from intragroup funding structures could be available because of the UK tax authority's approach to audits, believes Shiv Mahalingham of Chiltern
  • The year ahead is set to be action packed for tax markets around the world. Catherine Snowdon finds out about the fiscal hopes and fears around the globe
  • Marc Gerson: Being in Congress was a valuable experience but I am focused now on Miller After two years as majority tax counsel to the US House of Representatives Committee on Ways and Means, Marc Gerson has rejoined Miller & Chevalier. He joins the Tax Department and the Tax Legislative Practice of the Government Affairs Department as a Member.
  • Julian Fortuna: Had a wonderful opportunity to come over After 11 years as vice president and general tax counsel to InterContinental Hotels Group (IHG), the world's largest hotel group, Julian Fortuna has become the first tax partner at Duane Morris' Atlanta office.