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  • 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
  • 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
  • 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
  • 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
  • New thin-capitalization guidance released
    The German Federal Ministry of Finance issued administrative guidance in July 2005 setting out its interpretation of the recourse clause in the German thin-capitalization rules regarding third-party loans.
    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
  • chambers-oct05.jpg
    Savings directive fails ambitious target
    The EU Savings Directive, which Luxembourg has recently implemented, aims to allow member states tax the savings income of its residents according to national rules. However, a number of loopholes may prevent this goal, points out Paul Chambers of Atoz
    September 30 2005
  • Exchange of information needs protection for taxpayers
    Jeroen Adeler of Deloitte considers how the exchange of information agreements between the Netherlands Antilles, Aruba and the US can be improved to ensure that they protect the human rights of taxpayers
    September 30 2005
  • Time is running out for cash repatriation
    Taxpayers must decide quickly about section 965 of the American Jobs Creation Act. Marjorie Rollinson, Michael Mundaca and Jose Murillo of Ernst & Young analyze the guidance the Treasury and IRS has issued to help taxpayers make up their minds
    September 30 2005
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