Search results for

The English Court of Appeal has upheld the High Court ruling in favour of Revenue & Customs against 50 large US and Japanese multinationals trying to reclaim tens of millions of pounds of advance corporation tax. The Court of Appeal found that while advanced corporation tax breached relevant terms in the tax treaties, that part of the treaties had not been implemented by UK legislation. The decision enables the companies to appeal to the House of Lords on domestic law issues or to take the case to the European Court of Justice on points of European law

On January 1 Federal Law # 117-FZ of 22 July 2005 came into effect, which introduces certain tax allowances for residents of special economic zones (SEZs). This law is an essential extension of the Law on Special Economic Zones (# 116-FZ of July 22 2005), which governs the creation of SEZs in Russia.

On January 1 2006 the Ministry of Finance introduced two new sets of rules relating to the taxation of importation of goods to Poland. In general the purpose of the regulations is to apply a more taxpayer-friendly approach and create rules which would stop Polish importers from making customs clearances in neighbouring countries instead of in Poland. The government decided to make the changes because of the increased interest of Polish importers in the possibilities created by, for example, Czech postponed accounting system, combined with the exemption for supplies within bonded warehouses.

The Tax Arrangement for the Kingdom (the TAK) functions as a tax treaty between the Netherlands, the Netherlands Antilles and Aruba. The TAK limits the Dutch dividend withholding tax to 8.3% in case of a participation of 25% or more.

Effective from December 19 2005 Royal Assent was given to legislation which amends the operation of what is known as the section 23AG foreign employment income exemption.

The Indian Authority for Advance Rulings (AAR) recently examined whether a US pension trust is entitled to claim benefits under the India-US tax treaty for income from the sale of portfolio investments in India.

TEP is the alignment of tax and procurement strategy. The benefits stem from the optimization of indirect and direct tax and the minimization of the risk of not complying with tax legislation, explain Philip Davies and Nick Mühlemann of Ernst & Young

The ECJ judgment in Marks & Spencer will have an impact on the decisions to be taken by multinational groups with subsidiaries in different EU countries. Lovells' international tax team analyzes how various member states might deal with the verdict

The Mexican Congress passed thin-capitalization rules in 2005 to stop taxpayers using excessive debt to avoid tax. Roberto del Toro, David Cuellar and Francisco José Zamora of PricewaterhouseCoopers explain how the rules were relaxed in 2006

The use of allowable losses and disclosure, but little on tax reform, featured in the UK government's pre-Budget statement. Gary Richards of Berwin Leighton Paisner warns that the system's complexity might mean that taxpayers will choose to leave the country