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  • Taxpayers should be aware of the tax-effective methods available for investing into India and how India's tax treaties can be used for structuring inbound transactions, explain Srinivasa Rao and Rajendra Nayak of Ernst & Young
  • In response to taxpayer requests for guidance on the US tax treatment of cross-licence arrangements, the Internal Revenue Service (IRS) recently published Notice 2006-34, 2006-14 IRB 705, (the Notice), seeking information from taxpayers and practitioners on the substance of such transactions. Cross-licensing transactions are commonly entered into between parties who each own intellectual property (IP), often patents, and who wish to secure specified rights with respect to the IP owned by the other party. The motivations for entering into these arrangements vary, including, use of the other party's IP to develop a new product and averting potential infringement lawsuits that may arise from the exploitation of one's own IP (for example, licensing rights to a similar technology to avoid an infringement claim with respect to one's own IP).
  • Tax demands for oil industry Tax disputes in both Ecuador and Venezuela have underlined how some South American nations are using tax rates to increase the revenue they collect from oil companies.
  • The UK corporate tax community believed Gordon Brown, the UK chancellor of the exchequer, wasted the opportunity of his budget speech in March to simplify and enhance the competitiveness of the UK tax system.
  • Taxpayers should examine each merger and demerger opportunity carefully to obtain all the tax planning and efficiency benefits possible, explain Jairaj Purandare and Amrish Shah of PricewaterhouseCoopers
  • The Law "On Customs Tariff" is a basic law which regulates determination and declaration of the customs value of goods. It was first adopted in 1993. The amendments to the law come into force on July 1 2006.
  • John Neighbour: new move to KPMG John Neighbour, the former head of the OECD's tax treaty, transfer pricing and financial transactions division, has been made partner in KPMG's global transfer pricing practice. He will specialize in financial services work.
  • In recent years, some cities in Mexico have become attractive for foreign filmmakers to film all kind of movies. As such, the Mexican tax authorities issued certain rules to benefit this growing industry that not only generates jobs, but also some other benefits the cities in which the film is made (for example, improvements to the railways and an increase in tourism).
  • Issued on March 15, Draft Taxation Ruling TR 2006/D3, sets out the Australian Taxation Commissioner's preliminary view on what constitutes a "payment under a contract for works or related activities" for the purposes of withholding tax rules that apply for certain payments to non-residents. The draft ruling provides guidance as to when an obligation to withhold an amount arises.
  • The Business Council of Australia (BCA) has called for the recent review of Australia's tax system not to be a one-off.