ITR Search | International Tax Review

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

Evidence of economic substance is key to transfer pricing case

A recent case has made clear the risks for taxpayers in the Netherlands if they lack documentary evidence of the economic substance of intercompany transactions, warn Eduard Sporken and Hayden Aalvik of KPMG Meijburg & Co

March 31 2006

Corporate tax parity will happen in China by the end of year

China will enact a law during the present session of the National People's Congress to unify foreign and domestic corporate tax rates, according to Jiang Enzhu, a Congress spokesman.

March 31 2006

UK Budget takes up competitiveness agenda

The UK chancellor of the exchequer can no longer excite or surprise the country's multinational taxpayers with his annual budget statement. It is almost as if he does not want to.

March 31 2006

New London tax head at Clifford Chance

Nick Sherwin will be the head of Clifford Chance's tax, pensions and employment group in London from April 1. Sherwin has been a partner of the firm since 1993 and was previously head of the pensions group.

March 31 2006

Bennett Jones Toronto gets new partner

Catherine Brayley joined Bennett Jones' Toronto practice on March 22. Brayley deals with tax aspects of M&A, trusts and compliance issues as well as doing tax planning work for Canadian companies. Brayley is a member of the Ontario, and Newfoundland and Labrador bars.

March 31 2006

Duff & Phelps targets transfer pricing with former KPMG head

Steve Fortier: KPMG's new global leader of transfer pricing services Dan Peters: Keen to expand Duff & Phelps' transfer pricing capabilities The new leader of Duff & Phelps' transfer pricing practice plans to build teams of senior transfer pricing professionals in all significant centres in the US, particularly in the Boston to Washington, DC corridor.

March 31 2006

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

Savings agreement can be crucial for tax efficiency

International companies should examine the provisions of the savings tax agreement between the EU and Switzerland to benefit from the reliefs it contains, believe Armin Marti and Anna-Maria Widrig Giallouraki of PricewaterhouseCoopers

March 31 2006

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