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There are 33,160 results that match your search.33,160 results
  • IRS provides safe harbours for certain reorganizations subject to section 367(a)
    Taxpayers transferring assets to a foreign corporation are required, under certain circumstances, to file a gain recognition agreement (GRA) in conjunction with the transfer. GRAs are generally required to obtain tax-free treatment for certain outbound transfers of corporate stock and securities subject to section 367(a). See Treasury Regulation section 1.367(a)-3.
    November 01 2005
  • French court rules on compatibility of tax consolidation regime with EC Treaty
    A case has been brought in a French court questioning the compatibility of article 223A of the French Tax Code with the freedom of establishment. The rule stipulates that a company is not eligible for the tax consolidation regime unless 95% of its shares are held by the parent company.
    November 01 2005
  • Court verdict on the Sixth Directive trumps domestic law
    On October 12 2005 the Administrative Court in Warsaw issued a precedential verdict on the taxpayer's right to directly apply provisions of the Sixth Directive in a case where national legislation are contradictory to the relevant regulations of that Directive.
    November 01 2005
  • Are international rulings the way forward?
    Taxpayers in Italy now have another means of achieving certainty in their affairs. Maisto e Associati analyze how the international rulings procedure is to be applied
    November 01 2005
  • Changes to the capital gain participation exemption
    Law Decree 203 of September 30 2005, effective October 3 2005, provides for – inter alia – some changes to the Italian capital gain participation exemption (PEX) regime provided for by article 87 of the Italian Tax Code.
    November 01 2005
  • gebhardt-nov05.jpg
    What you should know about structuring transactions in Argentina
    Jorge Gebhardt, Carlos Casanovas, Sergio Caveggia and Gustavo Consoli of Ernst & Young consider how taxpayers should structure their M&A transactions in Argentina and what they should bear in mind when restructuring
    November 01 2005
  • Levob Verzekeringen BV, OV Bank NV v Staatssecretaris van Financiën
    Sixth VAT Directive – Articles 2, 5, 6 and 9 – Transfer of software recorded on a carrier – Subsequent customisation of the software to the purchaser’s specific requirements – Single taxable supply – Supply of services – Place of supply.
    October 26 2005
  • Portugal v Commission
    Reduction in tax rates for the revenue of legal and natural persons tax resident in the Azores.
    October 19 2005
  • Finanzamt Heidelberg v iSt internationale Sprach-und Studienreisen GmbH
    Sixth VAT Directive – Special scheme for travel agents and tour operators – Article 26(1) – Scope – Package comprising travel to the host state and/or the stay in that state and language tuition – Principal service and ancillary service – Definition – Directive 90/314/EEC on package travel, package holidays and package tours.
    October 12 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
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