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New tax network covers 19 countries

The Corporate Tax Alliance will comprise 13 tax specialist firms from Europe, three from Asia and the Americas.

October 01 2006

Changes to transfer pricing documentation on the way

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.

September 30 2006

New treaty-override to solve qualification conflicts

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.

September 30 2006

New rules on how to get tax-residency certification

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.

September 30 2006

What the new tax accounting rules mean

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.

September 30 2006

Tax tips for IP owners

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

September 30 2006

Dancing together

Deciding on which valuation system would prevail would be the issue if VAT, Customs and transfer pricing were to be integrated, believe Monique van Herksen, Folkert Idsinga and Gooike van Slooten of Baker & McKenzie

September 30 2006

Hong Kong and China DTA makes life easier for investors

Hong Kong: First port of call for investors into China? The double taxation agreement (DTA) between Hong Kong and China is expected to create opportunities for Hong Kong investors. The DTA, signed on August 21 between the HKSAR government and the Central People's government will offer Hong Kong investors protection against passive income, and further enhance the jurisdiction's place as a stepping stone for investors into China.

September 30 2006

Australia's Revenue aims to cut audit time

The Australian Taxation Office (ATO) has published its second Large business and tax compliance booklet, which says that the authorities will try to complete large audits within two years.

September 30 2006

Mission may be impossible

Multilateral action against arbitrage may not win the support of all governments, believes Chris Wales

September 30 2006

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