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  • joechan.jpg
    Hong Kong: Cross-border deals bring scrutiny
    Joe Chan and Catherine YW Tse of Ernst & Young Hua Ming, Hong Kong
    September 30 2006
  • nayak-oct06.jpg
    Ruling on taxability of a non-resident satellites service
    Rajendra Nayak Ganesh Pai The Delhi Income Tax Appellate Tribunal (ITAT) in the case of PanAmSat International Systems LLC vs. DCIT (Unreported) recently examined the taxability of consideration received by a non-resident from broadcasters, for use of transponder capacity of the satellite that enabled such broadcasters in transmission of their channels.
    September 30 2006
  • deltoro-oct06.jpg
    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
  • hasenauer-oct06.jpg
    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
  • Culture must drive a winning policy
    Having clearly defined functions within a company's tax department is crucial to a successful transfer pricing policy. The next step is implementation explains Herve Bidaud of Hogan & Hartson and Emmanuel Llinares of NERA Economic Consulting
    September 30 2006
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    UK rule change likely after EU court's Cadbury Schweppes verdict
    The European Court of Justice's (ECJ) ruling in Cadbury Schweppes is set to force the UK and other EU member states to change their laws on controlled foreign companies (CFC).
    September 30 2006
  • vanherksen-oct06.jpg
    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
  • 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
  • kersch-oct06.jpg
    Pfizer head of tax joins Grant Thornton
    Guy Kersch Guy Kersch, European head of tax for Pfizer, has left the pharmaceutical multinational to join Grant Thornton's growing transfer pricing practice.
    September 30 2006
  • Forum uncovers unusual relationships
    The recent GlaxoSmithKline (GSK) settlement with the IRS and taxpayer's continuing problems with intangibles were two of the issues that grabbed attention at International Tax Review's sixth annual Global Transfer Pricing Forum in London
    September 30 2006
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