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  • By Daniel Anghel and Malina Marinova of PricewaterhouseCoopers
  • 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.
  • 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.
  • 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:
  • 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).
  • 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).
  • By Roberto Carlos Rivas and Mirenchu Muñoz, PricewaterhouseCoopers
  • By Harun Can and Daniel Schafer of Lenz & Staehelin
  • By Tomasz Michalik and Marta Szafarowska, tax adviser of MDDP Michalik Dluska Dziedzic & Partners
  • Tomasz Michalik The Polish government has accepted the project of a new tax on cars, which is also called the ecological tax. The draft has been sent to the parliament and it is expected that the new legislation will be introduced from the beginning of 2007.