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Reits take shape in draft law

The German government has published its plans for real estate investment trusts. The Bill compares favourably to similar structures in other countries, reveals Martin Buenning of Allen & Overy

November 01 2006

Tax haven law blocks progress

The rules on preferred tax regimes need to change if local companies are to compete fairly with their international counterparts, believe Fred Barrett of PricewaterhouseCoopers and Timothy Cottrell of CEMEX

November 01 2006

Transfer pricing elite gather in London

The sixth Global Transfer Pricing Forum drew together the world's leading thinkers from governments, multinationals and their advisers for two days in London

November 01 2006

Changes in Luxembourg legislation create new opportunities

Samantha Nonnenkamp Specialized Investment Funds (SIFs) New draft law of specialized investment funds (SIFs) replaces the law on institutional investor funds to introduce more flexibility and extend the concept of eligible investors to professional investors and well-informed investors.

November 01 2006

Editorial

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

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

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

What to know about the calculation of indirect foreign tax credits

Akio Takisaki The Japanese tax system basically provides for two different kinds of tax credit: direct foreign tax credit and indirect foreign tax credit.

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

UK tax specialist gets new transfer pricing head

Chiltern has appointed Shiv Mahalingham as transfer pricing head. Mahalingham was at Ernst & Young before joining Chiltern.

October 31 2006

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