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  • The Tax Department is currently made up by seven partners and six senior associates, assisted by around forty five other tax lawyers from the offices of Madrid, Barcelona, Bilbao, Valencia, Lisbon, Porto and New York. The Department advises on all Spanish and Portuguese direct and indirect taxes, but has particular expertise in mergers and acquisitions, financial products and capital markets, International tax planning, real estate transactions and project finance, assurance and pension funds, internet and electronic business, high net worth individuals, stock options plans and alternate schemes and tax investigation and disputes.
  • Treasury and the IRS have requested information regarding cross-licence agreements (CLA) in connection with an IRS project to provide guidance on the tax consequences of participating in a CLA.
  • In the Cadbury Schweppes case the Advocate General (AG) to the European Court of Justice has stated in his opinion released on May 2 2006 that the UK controlled foreign companies (CFC) rules are prima facie a breach of the freedom of establishment set out in article 43 of the EC Treaty but may be justified on the grounds of needing to counter tax avoidance, as long as the legislation is targeted against wholly artificial arrangements intended to circumvent national law. The court is not obliged to follow the opinion of the AG but does so in most cases.
  • Switzerland is a known and well-established location for regional or global headquarters of large international groups. Typically the decision to set up a regional headquarter is driven by the business need to operate cost effectively in highly competitive and saturated markets.
  • To align the approach of the Russian court to the issue of abuse of tax legislation, the Supreme Arbitration Court prepared a draft informational letter that lists suspicious facts that are relevant to identification of bad faith taxpayers.
  • On May 2 2006 the Luxembourg government announced some changes in corporate income tax, income tax, value-added tax (VAT) and social security.
  • Over the last year there have been many updates on the plans for a reform of the Dutch Corporate Income Tax Act (CITA) as it was published in the white paper "Working on profit" in April of 2005. Recently the Dutch Ministry of Finance announced that a legislative proposal has now been sent to the Advisory Council for advice.
  • Enrique López of Deloitte Abogados y Asesores Tributarios describes how Spain has maintained its attractiveness for cross-border planning
  • President George W Bush's nomination of Eric Solomon as assistant secretary of the treasury for tax policy is expected to continue the simplification of the US tax code. Solomon, who is deputy assistant secretary for regulatory affairs and has been an important adviser to both the secretary of the treasury and the president since 1999, is expected to be ratified within the next three weeks.