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  • MyTravel plc v Commissioners of Customs and Excise
    Sixth VAT Directive – Scheme for travel agents – Package tours – Services bought in from third parties and in-house services – Method of calculating the tax.
    October 05 2005
  • Commission v France
    VAT – Deduction of input tax paid – Capital goods financed by subsidies.
    October 05 2005
  • Commission v Spain
    Failure of a member state to fulfil its obligations – Articles 17 and 19 of the Sixth VAT Directive – Subsidies – Limitation of the right to deduct.
    October 05 2005
  • Motorola, Ericsson and Nokia dispute PE decisiona
    The special bench of the tribunal (95 ITD 269) has examined issues relating to permanent establishments (PE) in India and the taxability of profits on offshore supply in response to an appeal by three foreign telecom suppliers, Motorola, Ericsson and Nokia.
    September 30 2005
  • Social security tax rules extended to Taiwanese, Hong Kong and Macau nationals
    On June 14 2005 The Ministry of Labour and Social Security (MLSS) issued new regulations (the Employment Regulations), regarding the administration of employment permits and social security requirements for Taiwan, Hong Kong and Macau nationals working in the People's Republic of China.
    September 30 2005
  • Employee share plans become more flexible
    The enactment of two resolutions in March 2005 by the National Monetary Council of the Central Bank of Brazil (BACEN) brought significant changes to the Brazilian exchange market and the foreign exchange control regulations. The resolutions also lifted many of the restrictions imposed on transfers of funds used to acquire shares of foreign entities.
    September 30 2005
  • New transfer pricing audit centre requests information
    The Belgian tax authorities manage a wide range of provisions, enabling them to investigate transfer prices and to adjust the tax base in case the arm's-length principle is not respected. They also published in 1999 an administrative circular letter, explaining to tax inspectors when and how a transfer pricing audit should be performed.
    September 30 2005
  • How foreign-resident trust beneficiaries can avoid capital gains tax
    The Australian Taxation Office (ATO) has confirmed in Interpretative Decision ATO ID 2005/225 that a foreign-resident beneficiary of a fixed trust is able to disregard certain capital gains attributable to it and in respect of its interest in the fixed trust even if the underlying capital gains tax (CGT) event happened to the trustee before March 21 2005.
    September 30 2005
  • The tax consequences of transferring business from a branch
    The new Company Law was enacted on June 29 2005, which includes a provision on so-called pseudo-foreign corporations. A pseudo foreign corporation is defined as a foreign corporation that has its principal office in Japan or a foreign corporation whose principal business activity is in Japan.
    September 30 2005
  • The benefits of Dubai's tax treaties
    Dubai's role for multinational business is expanding from a strategic trading centre to encompass more and more head-office service function (international human resources, information technology, treasury, finance, intellectual property, marketing and advertising). This update examines the tax drivers that are contributing to this trend.
    September 30 2005
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