Search results for

The UK government continues to focus on tax avoidance. The government has published a new national insurance contributions Bill that is aimed at combating avoidance.

One of the typical controversial issues in the Spanish tax system has traditionally been tax refunds to non-residents, where the refund is based on tax treaty provisions. This was contentious because under the Spanish General Taxation Law, resident taxpayers are entitled to claim a refund of any taxes incorrectly paid within a four-year period (before 1998, five years), a time limit that applied to non-residents, but only where they did not claim the refund under the provisions of a specific tax treaty (either because they were not resident in a country with which Spain had a tax treaty or because they were not entitled to it). In the latter case, the time limits were traditionally shorter.

It appears the National Tax Agency (NTA) is now taking the position that the Japanese tax-haven rule should be applied to certain Hong Kong subsidiaries of Japanese parent companies where the subsidiary operates its business under an arrangement of consignment manufacturing with a Chinese subcontractor.

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

Luca Dezzani of Dewey Ballantine discusses the issues a taxpayer must take into account when using an acquisition structure in a leveraged buy-out in Italy

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

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.

Reduction in tax rates for the revenue of legal and natural persons tax resident in the Azores.

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.

Sixth VAT Directive – Scheme for travel agents – Package tours – Services bought in from third parties and in-house services – Method of calculating the tax.