ITR Search | International Tax Review

Switzerland: Investors can profit from Swiss tax regimes

Switzerland has many advantages as a location for your holding company, not least its relatively low taxation of company income at the federal and cantonal levels, explain Markus Wyss and Catherine Morf of KPMG

May 31 2006

Colombia: What Colombia can offer foreign investors

Colombia's investment framework is attracting foreign attention. Jaime Vargas-Cifuentes of Deloitte outlines the issues and opportunities it presents

May 31 2006

Courts transmit mixed signals on anti-avoidance

The inconsistency and uncertainty of some court decisions on the interpretation of Canada's general anti-avoidance rule has not stopped the Canadian Revenue Agency from using litigation against tax avoidance, explains Trent Henry of Ernst & Young

May 31 2006

New decisions on international tax avoidance

In some cases, the tax authorities disallow a transaction that companies have legally structured based on the intention of the relevant parties. The tax authorities will argue that the transaction has been conducted purely for the purpose of avoiding tax and reconstruct the transaction from the perspective of economic substance. There have recently been several interesting Japanese court judgments on transactions and their economic substances in international taxation.

May 31 2006

Ireland: Ireland climbs rankings of holding company locations

Mary Walsh of PricewaterhouseCoopers argues the benefits of locating a holding company in her country

May 31 2006

Luxembourg: Soparfis take advantage of participation exemption

Keith O'Donnell of ATOZ outlines the advantages of using the Société de Participation Financière as a vehicle for holding activities

May 31 2006

De Danske Bilimportører v Skatteministeriet

Sixth VAT Directive – Article 11(A)(2)(a) and (3)(c) – Taxable amount – Registration duty on new motor vehicles.

May 31 2006

Beware of penalties from free trade agreements

The cost saving opportunities and regulatory risks of free trade agreements must be carefully considered when making strategic production and procurement decisions, believes Andrew Vanderwal of PricewaterhouseCoopers

May 31 2006

Rewe Zentralfinanz eG, as universal legal successor of ITS Reisen GmbH v Finanzamt Koeln Mitte

Tax legislation – Corporation tax – Offsetting of losses by parent companies – Losses due to a fall in the value of shares held in subsidiaries established in other member states.

May 30 2006

More multinationals are moving to low-tax locations

A KPMG survey of senior tax executives at large multinationals has found that 62% of respondents will be moving assets or operations to low-tax jurisdictions. This is a 13 % increase on last year's s survey figure of 55%. 120 tax executives were surveyed.

May 21 2006

Search results for