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  • New tax changes to the company law
    The new Company Law, which includes many drastic and significant changes in corporate legal treatments, will be effective from May 1 2006. The tax reform plan for 2006 also includes the following changes related to the new Company Law.
    March 31 2006
  • Tax authorities revise input VAT on capital goods
    Referring to the ECJ case C-378/02 of June 2 2005 (Waterschap Zeeuws Vlaanderen), the Belgian VAT authorities has revised its position regarding the recovery of input value-added tax (VAT) incurred on capital goods that were purchased by a VAT taxpayer in his former capacity of non-taxpayer (Administrative Decision ET 110.412 of December 20 2005).
    March 31 2006
  • liguori-apr05.jpg
    Alvarez & Marsal New York gets new managing director
    New managing director Albert Liguori joined Alvarez & Marsal's New York practice from Deloitte's global tax strategy team. Liguori has over 14 years experience of the tax aspects of corporate restructuring, M&A and post-merger integration.
    March 31 2006
  • Financial services investors win tax breaks
    On February 16 the Brazilian authorities issued Provisional Measure 281 (PM 281), which granted specific tax-breaks for foreign investors in the Brazilian financial market. The rules set forth by PM 281 can be summarized as follows.
    March 31 2006
  • Tax authorities create a new type of taxpayer: a regional presidency
    According to the Chilean IRS understanding, a regional presidency does not constitute a legal entity but a group of executives and regional directors who carry out their functions under a subordination liaison with a foreign company.
    March 31 2006
  • New tax carrots for internationally mobile, skilled labour
    Legislation providing a foreign income exemption to temporary residents of Australia was introduced into federal parliament on February 16 2006. The exemption is proposed to apply generally for income years beginning on or after the July 1 following the date of royal assent, except for the interest withholding tax exemption which is proposed to apply from the date of royal assent. The start date for the general measures is therefore likely to be July 1 2006, if royal assent is obtained before that date.
    March 31 2006
  • Why interest deductions are under scrutiny
    The Argentine tax authorities (AFIP) have been focusing, over the past few years, on the deduction of interest associated with loans granted by foreign lenders under certain conditions. Reasonably, the concern of the AFIP grows when it comes to interest and other financial charges stemming from loans received by local taxpayers from foreign related parties.
    March 31 2006
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    Careful tax planning can mean purchase benefits
    How an overseas taxpayer structures an acquisition in Brazil can lead to worthwhile tax savings. One planning strategy includes the use of the PMISI mechanism, according to Roberto Haddad of Branco Consultores
    March 31 2006
  • thomas-apr05.jpg
    Ways and means chairman to step down in November
    Bill Thomas: retires in November Bill Thomas, the outgoing chairman of the US House of Representatives' Ways and Means Committee, played a key role in two recent international tax controversies in the US. As the leader of the House tax-writing committee, he dealt with corporate inversions, where a US company converts into a foreign corporation to save taxes, and the US response to WTO's ruling against the Internal Revenue Code's extra-territorial income/foreign sales corporation provisions.
    March 31 2006
  • Federal tax holidays extended until the end of 2008
    On March 7 the Council of States unanimously confirmed the Swiss Economic Commission's decision to prolong the application of the Bonny Decree until the end of 2008. Companies planning to apply for the tax-privileged status may therefore feel a sense of relief, since the previously rumoured interruption of the Bonny Decree from July 2006 until 2008 is unlikely to occur.
    March 31 2006
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