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  • By Jeffrey Owens, OECD
  • Jeffrey Levenstam has resigned as Cisco Systems' senior director of international tax and customs, to become a member of Ernst & Young's international tax services group in San Francisco. Lisa Peschcke-Koedt, has left Agilent Technologies, where she was vice-president for global tax at Agilent, to replace Levenstam at Cisco.
  • In Switzerland corporate income taxes are levied at two different levels: federal level and cantonal level. Whereas the income of a Swiss company (or a branch) is subject to the same direct federal tax rate throughout Switzerland, the cantonal tax rates vary. In 2005, for ordinary income taxes, the canton Zug was top of the list of the most tax favourable cantons, followed by Appenzell and other cantons in Central Switzerland.
  • Nearly 20 years after the US Congress enacted legislative changes to Internal Revenue Code section 863(d) and (e) in the Tax Reform Act of 1986, a new set of proposed regulations governing the characterization and source of income from space and ocean activities and international communications activities were released in autumn 2005. (Proposed Regulations sections 1.863-8(h) and 1.863-9(l).) These proposed rules replace a previous set issued in 2001.
  • Although a tax reform is expected in 2006, the Spanish government has recently announced a previous anti-avoidance reform that will affect various taxes. The text made public is a Bill that will probably go under extensive changes during its parliamentary proceedings, but its most significant proposals may be summarized as follows:
  • Foreign firms in China may face fewer tax benefits from late 2006, as the government implements reforms that target its corporate income tax policy. In January, China announced a plan to offer a number of tax incentives to facilitate social and economic development in 2006.
  • 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:
  • The tax reform plan for 2006 was announced on December 19. The plan includes changes in the area of international taxation as follows:
  • The Belgian value-added tax (VAT) legislation foresees in the possibility that invoices are issued by the customer by derogation to the general rule that invoices are to be issued by the supplier of the goods or services (self-billing). In its administrative circular of December 8, the Belgian VAT authorities have now outlined the scope and the application modalities of the self-billing procedure. The administrative circular becomes effective retroactively as from January 1 2004.
  • 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