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  • How you can profit from tax effective procurement
    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
    February 01 2006
  • Member states start to get to grips with Marks & Spencer
    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
    February 01 2006
  • New general anti-avoidance rule in the works
    Proposed new section 103 South Africa has a general anti-avoidance rule (GAAR) in the form of section 103(1) of the Income Tax Act No 58 of 1962. In essence, a transaction can be attacked if there are four elements present:
    February 01 2006
  • Minister commits to low taxes
    Brian Cowen, the Minister for Finance, set the scene for the Irish Budget when, at a Thanksgiving lunch to the American Chamber of Commerce Ireland, he reiterated the government's commitment to low direct corporate and income taxes as key drivers of economic prosperity in Ireland. This approach was followed in Budget 2006, which was delivered on December 7 and which was very much a "steady as she goes" budget.
    February 01 2006
  • Changes to the foreign employment income exemption
    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.
    February 01 2006
  • Tax advisers feel heat of criminal indictments and the Supreme Court
    The criminal prosecution of tax advisers, the Pasquantino case and a toughened Circular 230 have combined to force US tax advisers to change how they deliver tax advice. Robert MacDonald and Vanessa Tollis of Gide Loyrette Nouel analyze the hazards
    February 01 2006
  • The benefits of keeping time options open in Marks & Spencer claims
    Taxpayers should be aware that time may still be on their side if they wish to make similar claims to Marks & Spencer. An analysis of other tax cases from the UK courts shows what is possible, explains Simon Whitehead of Dorsey & Whitney
    February 01 2006
  • Budget reconciliation is next for Congress' tax law writers
    The technical corrections legislation passed at the end of 2005 in the US will have an impact on international tax. Marjorie Rollinson and Michael Mundaca of Ernst & Young explain how this and budget reconciliation, yet to be agreed, will affect taxpayers in 2006
    February 01 2006
  • Lawmakers to reconsider thin capitalization rules
    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
    February 01 2006
  • Chancellor limits use of losses to refill coffers
    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
    February 01 2006
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