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  • Paul Davies: "More and more, HMRC are looking into whether tax information is documented correctly." Aidan O'Carroll: "What I want to do is to help the teams around the world, the biggest practices in particular, to work together." Paul Davies, who will take over from Aidan O'Carroll on July 1 as head of the UK tax group, has said that he considers tax accounting systems and controls the most important growth area for Ernst & Young's UK tax practice. O'Carroll will become the global tax leader for client services and accounts.
  • The Treasury Department and IRS in February 2006 issued final regulations (TD 9250) regarding the application of section 367 to cross-border stock transfers to which section 304 applies. The final regulations generally adopt rules that were proposed in May 2005, but with certain revisions.
  • 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.
  • 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.
  • On May 2 2006 the Luxembourg government announced some changes in corporate income tax, income tax, value-added tax (VAT) and social security.
  • The price for refined oil products in China has long remained at a lower level compared to the international market due to China's heavily regulated pricing system. With the international price of crude oil soaring since 2003, the disparity between the price of crude oil and refined oil products in the Chinese market has increased. This could lead to a number of potentially damaging outcomes controlled.
  • On April 27 2006 ECJ Advocate General Geelhoed issued his opinion in Denkavit International BV and Denkavit France SARL (case 170/05). He states that the withholding tax that France applied to outbound dividends whereas domestic distributions would be almost totally exempt is in breach of article 43 of the EC Treaty.
  • On May 2 2006 the new Conservative government tabled its first federal Budget. Included was a rate reduction in the federal goods and services tax from 7% to 6%, as well as a number of prominent tax measures affecting business, namely a reduction in the general corporate tax rate and the elimination of the corporate surtax and federal capital tax.
  • July 1 sees the start of a significant expansion of the Tax Avoidance Disclosure regime in the UK. Richard Collier-Keywood, of PricewaterhouseCoopers explains what the new regulations aim to capture and comments on whether they are likely to be successful
  • Joel Walters, the new leader of Vodafone's tax department, tells Ralph Cunningham about the role and how it fits in with the rest of the company