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  • 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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    Conduit entity rules are key to IP planning
    New rules on royalty conduit entities have implications for tax planning in the Netherlands involving intellectual property rights. Jos Peters of Rima Marlyn analyzes how the rules work and what issues litigation has highlighted
    September 30 2005
  • Courts exert more influence on tax system
    An increasing amount of jurisprudence and the tax protocol to the CECA with India have been the features of tax developments in Singapore in 2005, according to Nand Singh Gandhi, Yeoh Lian Chuan and Lim Pek Bur of Allen & Gledhill
    September 30 2005
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    Transfer pricing audits get off to tentative start
    India's tax authorities have completed the first year of transfer pricing audits. They need to clarify many issues before the system can be said to be working smoothly, argues Vispi Patel of Deloitte, Haskins & Sells
    September 30 2005
  • Dutch and UK treaties offer zero withholding tax on dividends held through hybrids
    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.
    September 30 2005
  • Transfer pricing documentation requirements clarified
    The enabling legislation to bring the transfer pricing and thin-capitalization rules into the South African Income Tax Act was passed in 1995.
    September 30 2005
  • Withholding tax on repurchased shares clarified
    When Dutch resident companies repurchase their shares, the amount paid in excess of the paid-up capital on these shares is considered a profit distribution subject to Dutch dividend withholding tax. These shares are subsequently considered as redeemed for tax purposes. If, however, the repurchase of shares can be considered a temporary investment for the company, no dividend withholding tax is due and the shares can be capitalized as assets.
    September 30 2005
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    Microsoft's Boyle takes TEI helm
    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
    September 30 2005
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    Input VAT recovery in Latin America: credit where it is due
    Latin American governments rely very heavily on VAT revenues and are reluctant to give them back in credits and refunds. Julián Martín and Torsten Fetzer of KPMG in Argentina explain the region's complex VAT credit regimes
    September 30 2005
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