ITR Search | International Tax Review

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

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

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

How to deal with M&A transactions/LBOs in Switzerland

Reto Savoia and Stefan Kuhn of Deloitte discuss certain key aspects of M&A transactions/leveraged buy-outs in Switzerland in light of the current tax environment

March 31 2006

Italy: The effect of current tax law on structuring Italian M&A

By Massimo Agostini and Paola Albano, Gianni, Origoni, Grippo & Partners

March 31 2006

Aro Tubi Trafilerie SpA v Ministero dell’Economia e delle Finanze

Directive 69/335 – Indirect taxes on the raising of capital – National legislation providing for the charging, in the case of a ‘reverse’ merger, of a proportional registration tax of 1% of the value of such a transaction – Classification as capital duty – Increase in capital – Increase in the assets of the company – Increase in the value of shares – Provision of services by a member – Decision to merge made by the members of the member.

March 29 2006

Uudenkaupungin kaupunki

VAT – Deduction of input tax – Capital goods – Immovable property – Adjustment of deductions.

March 29 2006

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