ITR Search | International Tax Review

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

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 pitch gets Yankees and Mets off-field success

The Yankees and the Mets, New York's two Major League Baseball teams are financing moves to new stadia with an innovative tax-exempt bond structure. Claire Jones looks at the structure's development and why it could change how the construction of sports grounds are financed in the US

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

What the transfer pricing changes do

Henry An Jin-Young (David) Lee The Korean transfer pricing regulations are contained in the Law for the Coordination of International Tax Affairs (LCITA), which has been in effect since January 1 1996. The Ministry of Government Legislation announced amendments to the LCITA on May 24 2006 and underlying Presidential Enforcement Decree (PED) on August 24 2006.

September 30 2006

Changes to the general-anti-avoidance rule

Peter Dachs The general-anti-avoidance rule (GAAR) is contained in section 103 of the Income Tax Act. The present test has essentially four requirements that must all be fulfilled before there is tax avoidance.

September 30 2006

Tax particularities for new projects or expanding investments

By Luis Liñero, Deloitte

September 30 2006

A region competing to attract capital

By Manuel Solano, Ernst & Young

September 30 2006

Introduction

Latin America is back in business. After the financial malaise of the past decade, the continent has turned the corner and is rapidly shaping up to compete with other dynamic regions of the world, particularly Asia, to attract foreign investors.

September 30 2006

ATO to reframe risk and relationship management with large business

Neil Wilson The release of the Australian Taxation Office's (ATO) Large Business and Tax Compliance booklet on August 30 2006 marks a critical juncture in the Australian tax system for large business. A good way to start to understand what will attract the ATO's attention is to consider the seven high-level propositions for risk identification and risk profiling.

September 30 2006

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