ITR Search | International Tax Review

Korea - Transfer pricing audits in Korea take off

By Dong-Jun Yeo and Stefan Moller, Kim & Chang

September 30 2005

Employee share plans become more flexible

The enactment of two resolutions in March 2005 by the National Monetary Council of the Central Bank of Brazil (BACEN) brought significant changes to the Brazilian exchange market and the foreign exchange control regulations. The resolutions also lifted many of the restrictions imposed on transfers of funds used to acquire shares of foreign entities.

September 30 2005

New transfer pricing audit centre requests information

The Belgian tax authorities manage a wide range of provisions, enabling them to investigate transfer prices and to adjust the tax base in case the arm's-length principle is not respected. They also published in 1999 an administrative circular letter, explaining to tax inspectors when and how a transfer pricing audit should be performed.

September 30 2005

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

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

Ministero dell’Economia e delle Finanze, Agenzia delle Entrate v FCE Bank plc

Sixth VAT Directive – Articles 2(1) and 9(1) – Services supplied within the same legal entity – Fixed establishment – Transactions not chargeable to VAT – OECD Double-Taxation Convention – Charging of cost of services supplied against profits made in the host state through the fixed establishment – No relevance for purposes of VAT.

September 28 2005

Jyske Finans A/S v Skatteministeriet

Preliminary ruling – Vestre Landsret – Interpretation of Articles 11.A(1)(a), 13.B(c) and 26a.A(e) of Sixth Council Directive 77/388/EEC on the harmonisation of member state laws relating to turnover taxes – Common system of value added tax: uniform basis of assessment – Tax on the resale of motor cars purchased second‑hand and without tax by a leasing company from individuals for the purpose of leasing them out (sale and leaseback).

September 21 2005

Uudenkaupungin kaupunki

Sixth VAT Directive – Deduction of input tax– Adjustment – Capital goods – Immovable property.

September 14 2005

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