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What the tax treaty with Israel offers

Following the publication of the Decree 931 on September 16 2005, the tax treaty for the avoidance of double taxation and the prevention of fiscal evasion concluded between Brazil and Israel has entered into force. The provisions of the treaty will apply as of January 1 2006.

November 01 2005

The notional interest deduction becomes clearer

The Royal Decree of September 17 2005 (Belgian Official Gazette of October 3 2005) has provided some clarifications about the Law of June 22 2005 introducing a risk capital deduction (or notional interest deduction).

November 01 2005

Software licence payments arouse controversy

In Argentina non-residents are subject to income tax exclusively on their Argentine-source income. Pursuant to this rule, the non-resident pays tax through a 35% withholding tax levied on a deemed net income equivalent to a percentage of the gross payment received. Unless provided otherwise in the Income Tax Law, 90% of the gross revenue derived by the non-resident from Argentine source is deemed taxable net income, which gives rise to an effective 31.5% withholding tax.

November 01 2005

Barcelona attracts transfer pricing's leaders

Delegates from around the world debated the latest issues in transfer pricing, including intangibles and allocation of profits, at International Tax Review's fifth annual Global Transfer Pricing Forum in Barcelona at the end of September

November 01 2005

Netherlands and Isle of Man sign tax pact

Agreements on exchange of information, transfer pricing, and commitments to a double taxation treaty, feature in the deal that the Isle of Man has struck with the Netherlands. The agreement is the first of a number of similar packages the Isle of Man expects to conclude in the next six months.

November 01 2005

Why withholding taxes are under threat

These are indeed troubled times for governments that rely heavily on withholding taxes for revenue. After Fokusbank decided by the European Free Trade Area (EFTA) court (E-1/104) and the pending case Denkavit (C-170/05), more and more decisions can be expected from local judges questioning the right of withholding in cross-border situations.

November 01 2005

Withholding tax relief for foreign holding companies

Foreign corporate recipients of German-source dividends are often exempt from German dividend withholding tax under the terms of tax treaties and, within the EU, under the Parent-Subsidiary Directive. However, the exemption or a reduced tax treaty withholding rate may be precluded by the anti-abuse provisions of section 50d(3) EStG (German Income Tax Law).

November 01 2005

Kodak takes tax hit

A $900 million tax charge contributed to Eastman Kodak posting a fourth-quarter loss of $1.03 billion in October. This was directly related to the firm's attempts to become a digital products and printing service provider.

November 01 2005

Implications of the conduit foreign income regime for foreign investors

The new conduit foreign income (CFI) rules (previously released by Treasury as an Exposure Draft in June 2005), are designed to remove an Australian tax liability on foreign sourced income, where that income is ultimately distributed to non-resident investors. They are aimed at improving Australia as an investment choice for foreign investors.

November 01 2005

German authorities take favourable views on investment law questions

The Federal Ministry of Finance brings more legal certainty for investors, argue Florian Schultz and Martina Kästle of Linklaters Oppenhoff & Rädler

November 01 2005

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