ITR Search | International Tax Review

How tax planning made its comeback

By Daniel Caracciolo and Pablo Tonina of Deloitte, Buenos Aires

September 30 2006

VAT challenges in Russia

By Paul Tobin, PricewaterhouseCoopers

September 30 2006

What the ECJ's N decision means for Dutch exit taxes

Following the preliminary ruling issued by Gerechtshof te Arnhem on the compatibility with the EC Treaty of exit taxes levied by the Netherlands on an individual with a substantial shareholding in a Dutch company transferring his residence, the ECJ ruled on September 7 2006 in favour of the plaintiff with regard to these exit taxes.

September 30 2006

Changes in the double tax treaty with France

Samantha Nonnenkamp Luxembourg and France have initialled a protocol amending the real estate income provisions of the double tax treaty concluded on April 1 1958.

September 30 2006

A new age in indirect taxation in Romania and Bulgaria

By Daniel Anghel and Malina Marinova of PricewaterhouseCoopers

September 30 2006

New rules on the deductibility of directors' remuneration

Akio Takisaki Under the 2006 tax reforms, the rules on the deductibility of a director's remuneration have changed drastically. According to the revised corporate tax law, the following three types of directors' remuneration can be deducted as expenses of a corporation.

September 30 2006

Withholding tax drops on aircraft leases and tax debt changes

Nélio B Weiss Philippe Jeffrey As discussed in a previous column in this publication, the Brazilian authorities issued on August 3 2006 Provisional Measure 315, which introduced important changes to the foreign exchange legislation. It allowed Brazilian exporters to keep up to 30% of their total export revenues abroad and allowed Brazilian subsidiaries to register in local currency the foreign capital that has not yet been registered with the Brazilian central bank.

September 30 2006

New residence rules for foreign holding companies

Massimo Agostini Pursuant to article 73, paragraph 3 of the Italian Tax Code a company is generally considered to be resident in Italy for income tax purposes if either:

September 30 2006

IRS proposes new foreign tax credit rules

Sean Foley The US Treasury Department and the IRS have proposed significant revisions to the regulations under Internal Revenue Code (IRC) section 901 regarding who is considered to pay a foreign tax for purposes of the US foreign tax credit (see REG 124152-06).

September 30 2006

ECJ backs regional tax regimes in the Azores case

Daniel Armesto In its judgment of September 6 2006, the European Court of Justice (ECJ) has confirmed the European Commission's position with regard to the classification as state aid of the income tax rate approved by the regional Government of Azores, Portugal (C 88/03).

September 30 2006

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