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  • Elizabeth Kessenides: new in New York office Ian MacGregor: moved from government Osler, Hoskin & Harcourt, a Canadian law firm, has added two new partners to its tax practice.
  • The long-promised Proposed Cost Sharing Regulations (REG-144615-02) were finally released August 22 2005. The proposed regulations, if finalized in their current form, will represent a dramatic re-writing of the US rules governing qualified cost sharing arrangements (CSA).
  • At present Swedish tax law does not contain any requirements for specific transfer pricing documentation. However, in the Finance Bill for 2006 (2005/06:1), that was presented to parliament by the government on September 20 2005, some light is shed on the future.
  • On January 1 2006 the provisions of the Tax Ordinance contained in a new section entitled "Agreements with respect to calculation of transaction prices" will come into force. The provisions introduce the possibility for taxpayers to enter into pricing agreements (APAs) with tax administration on application of selected transfer pricing method to transactions between related parties.
  • Anumber of significant developments occurred in Russian value-added tax (VAT) legislation recently. The amendments were introduced to the VAT chapter of the Russian Tax Code by three federal laws signed by the President of Russia on July 22 2005.
  • There have been two new Supreme Court tax rulings in Norway. They both concern losses on loans to subsidiaries. Combined with the new exempt-method for losses on shares, the cases, to some extent, turn Norwegian tax thinking up-side-down.
  • For several years a tax incentive has been in force in the Mexican Income Tax Law (MITL), which allows Mexican taxpayers to claim a credit for the expenses incurred in connection with technological research and development (TR&D) projects. The most recent update of the rules for the application of this benefit have been published in the Official Gazette providing some guidance for its application.
  • Torsten Fetzer (KPMG's regional contact for Latin America) – KPMG in Argentina
  • By Luis Liñero, Deloitte
  • By Geoffrey Soh, KPMG in Singapore