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  • The tax treatment of some so-called flow-through entities (S Corporations and limited liability companies or LLCs for example) has been always an issue under the Mexico – US tax treaty. As it stands now, under a protocol to the treaty, a partnership, state or trust is a resident of a contracting state only to the extent that the income it derives is subject to tax in that state, as the income of a resident, either through the partnership, state or trust or its partners or beneficiaries.
  • Non-residents are increasingly using unlimited liability companies to structure Canadian investments tax efficiently. McMillan Binch Mendelsohn and Honigman Miller Schwartz and Cohn explain the advantages offered by the use of such entities
  • Michael Carmody: specialists will help ATO More use of technical experts in the ruling process and greater involvement by taxpayers in risk reviews and audits are part of the overhaul of corporate audit procedures announced by Michael Carmody, the commissioner of the Australian Taxation Office (ATO) in October.
  • Corporate attitudes to tax risk in the UK have changed significantly over the past two years according to a Deloitte survey of 90 tax directors from FTSE 350 companies.
  • Commissioner Kovacs: wants a single EU corporate tax base by 2009 at the latest EU tax commissioner, Laszlo Kovacs, said that the European Commission aims to present legislation that would create a uniform corporate tax base by 2008 or 2009 pursuant to the Lisbon strategy to boost EU growth.
  • The European Commission has announced a plan to propose a code of conduct for transfer pricing documentation by the end of 2005.
  • Germany's new coalition government has postponed outgoing chancellor Gerhard Schröder's planned effective corporate tax cut from 38.7% to 32.7% from the beginning of next year to 2007, making it part of a broader package of tax reform. German press reports also claim the coalition plans to raise the value-added tax (VAT) rate from 16% to 18%.
  • At a speech in Zurich on October 21, EU tax commissioner, Laszlo Kovacs, said that the European Commission plans to work with financial centres outside of the EU, such Hong Kong and Singapore, to encourage them to adopt measures contained in the Savings Directive.
  • Barclays announced on October 21 that it has appointed Dario Garcia as the new global head of value-added tax (VAT) in London.
  • George Osborne, opposition chancellor of the exchequer, or finance minister, in the UK, has launched a tax reform commission aimed at improving the economic efficiency, transparency, simplicity and fairness of the British tax system.