Search results for

Leandro Passarella has moved from Negri & Teijeiro in Buenos Aires to Estudio Garrido as head of tax. Although he focuses mainly on inbound and outbound investments, he will be involved in overseeing the full range of the practice's tax mandates. He worked for PricewaterhouseCoopers in New York office before joining Negri & Teijeiro.

Elizabeth Kessenides: new in New York office Ian MacGregor: moved from government Osler, Hoskin & Harcourt, a Canadian law firm, has added two new partners to its tax practice.

Under the US-UK Income Tax Treaty (the UK Treaty), a UK corporation is not subject to US withholding tax on dividends received from a US corporation if the UK corporation has owned at least 80% of the voting power of the shares in the US corporation for the 12-month period ending on the dividend declaration date.

At the time of the budget (March 2005), the UK government published a discussion paper about real estate investment trusts (REITs). This followed on from a previous consultation in 2004. The government has indicated that it may introduce legislation for REITs in the Finance Bill 2006, but this is subject to it resolving a number of potentially difficult issues. In September there were conflicting reports about the government's enthusiasm for the proposals, some indicating they could be dropped altogether.

At present Swedish tax law does not contain any requirements for specific transfer pricing documentation. However, in the Finance Bill for 2006 (2005/06:1), that was presented to parliament by the government on September 20 2005, some light is shed on the future.

The Spanish media have recently reported of a significant reform in the transfer pricing legislation. The tax authorities are the source of the information but no drafts have been issued yet. Although the changes anticipated are still unofficial, a significant reform seems to be sought.

There have been two new Supreme Court tax rulings in Norway. They both concern losses on loans to subsidiaries. Combined with the new exempt-method for losses on shares, the cases, to some extent, turn Norwegian tax thinking up-side-down.

EU: provisions are unacceptable in view of the large benefits involved The US is likely to appeal the decision of an WTO dispute resolution panel on September 30 that it is still in breach of the recommendations of the organization's Dispute Settlement Body regarding American foreign sales corporation/ extra-territorial income rules. This is despite changes brought in by 2004's American Jobs Creation Act (AJCA). The WTO believes that the transitional nature of the rule changes still violate world trade rules.

Sed Crest discovers what drives Microsoft's corporate vice-president of finance, Michael Boyle, and his plan for the Tax Executives Institute as he takes on the role of international president

The VAT model has reached China. Khoonming Ho and Jesse Wang of KPMG in China and David Stevens of KPMG in Hong Kong describe problems with its introduction and predict an easy VAT conquest of Hong Kong