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  • Denkavit International BV, Denkavit France SARL v Ministre de l’Economie, des Finances et de l’Industrie
    Tax legislation – Tax on distributed dividends – Exemption for distributed dividends – Possibility of crediting tax against tax due in another member state.
    April 26 2006
  • India claims back taxes from multinationals
    The Indian income tax authorities have demanded Rs500 million ($11 million) from a foreign bank as a result of investigations under the transfer pricing audit regime. According to the Times of India on April 24, the tax claims the authorities have made against multinational corporations amount to Rs2.5 billion. The report said that 1,000 MNCs were investigated in 2005 and about a quarter were judged to have evaded tax.
    April 23 2006
  • Wolf Theiss hire tax specialist
    Michaela Klar has joined Wolf Theiss' tax practice in the firm's Vienna office. As well as corporate tax law and international tax law, she specializes in the taxation of financial instruments. She previously worked for Freshfields Bruckhaus Deringer
    April 23 2006
  • Musher fills international IRS role
    Steven Musher was finally confirmed as associate chief counsel (international) of the US IRS on April 14 He took up his new position two days later, having been appointed acting counsel in November 2005. Before then, Musher was deputy associate chief counsel where he oversaw the published guidance programme.
    April 23 2006
  • New corporate tax head for VNU
    Matthew O'Laughlin is the new head of corporate tax at VNU, a global media company. O' Laughlin, who is based in New York, replaces Bart Kuper. Kuper has joined TNT, a mail delivery company, as group tax director.
    April 23 2006
  • Software company gets $1 billion bill
    The IRS hit Symantec, a US software security firm, with a demand for $1 billion in April 17. The tax bill came to $900 million with an extra $100 million in interest and penalties. Most of the charges relate to Veritas, a software company that Symantec bought in December 2004.
    April 23 2006
  • Lone Star donates $106 million as Korean authorities begin tax probe
    Lone Star, a US investment fund, has donated W100 billion ($106 million) to Korea from the profits of the sale of Korea Exchange Bank. The Korean authorities are investigating Lone Star as part of a tax probe into offshore funds, which began on April 24.
    April 23 2006
  • US tax shelters ruled invalid
    David Laro, a judge at the US Tax Court ruled on April 18 that the tax shelters known as the Son of Boss are invalid. Son of Boss refers to shelters such as foreign leveraged investment programmes (FLIPS), offshore portfolio investment strategies (OPIS), bond linked issue premium structures (BLIPS) and market linked deposits (MLDS). The first three structures are at the centre of the government's tax shelter litigation against ex-KPMG employees.
    April 23 2006
  • UK authorities publish large business model
    HM Revenue & Customs (HMRC) published 'Working with large business – operating model' on April 18. The paper sets out the model for communication between business and the authorities.
    April 23 2006
  • HMRC adviser moves to KPMG London
    Former HMRC tax adviser, Gavin Bate, joined KPMG on April 20. Bate moves to the research and development tax team from his public sector role as senior technical adviser.
    April 23 2006
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