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  • Why the finance ministry withdrew the Fokus Bank appeal
    The Norwegian government has withdrawn its appeal to the Norwegian Supreme Court in the Fokus Bank case. Fokus Bank won its case before the Norwegian Appeal Court in May 2005 after the EFTA Court had given its opinion in case E-1/04 of November 23 2004 that the Norwegian withholding tax regime on dividends was conflicting with article 40 of the EEA Agreement (which mirrors article 56 of the EC Treaty).
    March 31 2006
  • What the ECJ's Halifax ruling means
    The European Court of Justice has recently given its ruling in the Halifax case. It stated that:
    March 31 2006
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    US: Authorities learn from market on taxation of credit default swaps
    By Eva Farkas-DiNardo, Alston & Bird
    March 31 2006
  • Editorial
    The nature of M&A means transactions are likely to be cross-border and complex. Tax authorities in different jurisdictions do not always use the same criteria for the treatment of the same structure. That makes it imperative that international businesses receive world-class tax advice to help them through the task of dealing with the complex M&A tax rules that some countries have enacted.
    March 31 2006
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    Australia: The debt/equity rules four years on - clarity or confusion?
    By Peter Collins, Michael Frazer and Chris Morris of PricewaterhouseCoopers
    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
  • New securities law changes taxation of participation units in investment funds
    The new Securities Law, which entered into force on October 24 2005, introduces certain changes into a number of binding regulations, including both the personal and corporate income tax acts, which can be beneficial for taxpayers in 2006.
    March 31 2006
  • Understanding the new APA rules
    An advance pricing agreement (APA) is a procedural tool that offers multinational taxpayers the opportunity to address their related-party transactions in a proactive manner. Less than two years after the release of the previous APA revenue procedure, the Internal Revenue Service (IRS) has once again published an update to the rules for obtaining an APA.
    March 31 2006
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    Flat tax: An alternative for Switzerland?
    The introduction of a flat tax in other parts of Europe should make the authorities consider the benefits of bringing the concept to Switzerland, believes Andrin Waldburger of PricewaterhouseCoopers
    March 31 2006
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    Mexico: Planning business expansions into Mexico
    By Fred Barrett and Adriana Rodriguez, PricewaterhouseCoopers, Mexico City
    March 31 2006
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