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Editorial

Welcome to the special feature on Italy in the November issue of International Tax Review.

November 01 2006

Get ready to survive an audit

Horacio Dinice and Manuel Diskenstein of Deloitte explain how the burden of gathering transfer-pricing information falls squarely on the taxpayer's shoulders

November 01 2006

Decree on transfer of functions expected

Lorenz Bernhardt Jobst Wilmanns Following the transfer pricing documentation rules in 2005 and the new arrangements for advance pricing agreements this October, the finance ministry has turned its attention to examining the substance of specific transactions. The first item on the agenda is the transfer of functions abroad, prompted by fears, real or imagined, of multinationals shifting as much as possible of their business to low-cost, low-tax countries as a deliberate policy of avoidance.

November 01 2006

European Court opposes UK's CFC rules in Cadbury Schweppes

Peter Cussons On September 12, the Grand Chamber of the European Court of Justice handed down its judgment in the Cadbury Schweppes Plc Controlled Foreign Companies (CFC) case. The ECJ has remitted to the UK referring court (the Special Commissioners) the question as to whether the UK motive test can be interpreted so that the UK CFC charge on the UK immediate parent company of an EU (non-UK) lowly taxed (less than 75% of the UK rate ) subsidiary only applies in the case of "wholly artificial arrangements".

November 01 2006

2007 Tax Package unveiled on Budget Day

Each year, the third Tuesday of September, is Budget Day in the Netherlands. On this year's Budget Day, September 19, the 2007 Tax Package was published. The majority of the proposals included in the 2007 Tax Package will take effect from January 1 2007.

November 01 2006

Italian surprise and German disappointment at European Court

An unexpected verdict on Italy's IRAP tax and a damaging second opinion for the German finance ministry made October a critical month for tax decisions at the European Court of Justice (ECJ).

November 01 2006

Mergers let tax firms offer more

KPMG member firms in Germany and the UK have announced a plan to merge to form a single entity, KPMG Europe LLP. Meanwhile, Deloitte has also announced a merger between its UK and Swiss member firms. While the two mergers are unrelated they do hint at a developing trend towards pooling tax resources in Europe.

November 01 2006

Editorial

In hindsight, November 1 2005 turned out to be a significant disappointment for the US tax community. The hand-over of the report of the Advisory Panel on Federal Tax Reform to the Treasury on that day was billed as the beginning of a process of simplification of the Internal Revenue Code.

November 01 2006

Production tax gets by EC challenge

The ECJ has ruled that Italy's regional tax on production is not the same as VAT. Silvia Medici and Luca Dezzani of Dewey Ballantine review the judgment

November 01 2006

New Mexico-Canada tax treaty

Roberto del Toro Mauricio Sellerier The governments of Mexico and Canada have agreed to renegotiate the current Mexico-Canada income tax treaty which was originally signed in 1991. The new treaty was signed on September 12 2006 and it is expected that such treaty will enter into force as from January 2007 after the corresponding governments exchange notes through diplomatic channels.

November 01 2006

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