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  • Eugene Sitarz, formerly tax department director, has become vice president, tax at the Ohio utility company
  • ANZ, an Australian financial services group, and the Australian Tax Office announced on September 29 that they had reached agreement on a Forward Compliance Arrangement to cover the bank's compliance requirements under the goods and services tax, for an initial three-year trial period. ANZ is the first Australian company to enter into such a set-up, which is aimed at large corporates and is considered to be "an alternative" to ATO audits, and "requires a commitment of continuous disclosure to the Tax Office".
  • Francesca Lagerberg is leaving Smith & Williamson to join Grant Thornton as head of its new national tax office in the UK. Lagerberg, the chairman of the tax faculty of the Institute of Chartered Accountants of England and Wales, will be responsible for providing technical know-how to the firm's tax practice
  • The European Commission will propose a "relatively modest solution" to the "problem" of the cross-border treatment of losses when it publishes a communication on the topic in the near future, according to Laszlo Kovacs, commissioner for taxation and customs union. In a speech at a dinner put on by CFE, the confederation of European tax advisers, during its general assembly in London, Kovacs also said the Commission would have to make some choices when it comes to putting forward its proposal on a common consolidated corporate tax base. "By its very nature, a common tax base cannot exactly match the current tax bases of the 25 Member States." he said.
  • The Corporate Tax Alliance will comprise 13 tax specialist firms from Europe, three from Asia and the Americas.
  • Hans Olav Hemnes Morten Beck The Ministry of Finance is now preparing a green paper on transfer pricing documentation rules. This is expected to be published later this autumn. It is anticipated that the proposed legislation will be in line with the EU Transfer Pricing Documentation Code of Conduct.
  • Jan Becker Sebastian Hölscher The Annual Tax Bill 2007 will introduce a switch-over clause into German tax law denying a treaty exemption to German residents if, due to differing legal definitions of income, the other country either does not tax the respective income at all, or only by withholding. The same will apply where the other country does not tax the income because it does not see the recipient as its own tax resident.
  • Roberto del Toro Marco Nava A basic rule that taxpayers must follow in order to apply a benefit contained in a tax treaty for the avoidance of double taxation is to demonstrate its tax residency. In this connection, there was no specific guidance for Mexican taxpayers to obtain a Mexican tax residency certification.
  • Clemens Hasenauer Johannes Prinz Following the various changes in the Austrian tax system over the past years further tax legislation has been passed this year (Strukturanpassungsgesetz 2006, KMU-Förderungsgesetz 2006, Betrugsbekämpfungsgesetz 2006, Immobilien-Investmentfondsgesetz-Novelle). Some of the recent amendments are highlighted below.
  • Multinational enterprises often allocate the ownership of IP among their group companies with more regard to legal than to tax issues. Karen Hughes and Domenico Borzumato consider how companies can achieve greater tax efficiency when managing their IP internationally