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  • By Jayesh Sanghvi and Narendra Rohira, Ernst & Young in India
  • By Christopher Scott (UK), Tom Garigliano (US) and Mark Baldwin (Japan)
  • By Tony Urwin (UK), John Bardsley (Australia), Jason Chang (Australia) and Sylwester Grochowina (Poland)
  • By Tristram Roberts (UK) and Guus van Eimeren (Netherlands)
  • Global financial services – Industry lax leaders Banking
  • Under the imputational corporate tax credit system in force in Germany until 2001/02, the double taxation of corporate earnings was avoided by granting dividend recipients - corporations and individuals - a credit for the corporate income tax paid by the distributing corporation. The credit was, however, in general only available with respect to dividends paid and received by a German resident.
  • The US Treasury and the Inland Revenue Service (IRS) on June 23 made available the draft version of the 2005 schedule M-3, which deals with income and loss reconciliation for companies with assets over $10 million. They also released instructions for form 1120, the US corporate income tax return.
  • During the 1990s foreign investors looked to expand their businesses in Brazil in a number of key sectors of the economy. The main factors taken into consideration by foreign investors were, among others, the economic stabilization with reduced inflation rates, the opening of the Brazilian market, the attractive market conditions and the reduction of the Brazilian sovereign risk rates due to economic stabilization.
  • Under the Austrian participation exemption dividends received by an Austrian resident corporate shareholder from a domestic company are tax exempt irrespective of the percentage of the participation and of the holding period. In contrast, dividends from a foreign company are only tax exempt if the shareholder holds at least 10% in the share capital of a foreign company eligible for such exemption and if such participation is being held continuously for at least one year.
  • Michel Guilluy, Eric Centi and Vincent Marquis of PricewaterhouseCoopers, examines the interaction between the MFN clause and the fundamental freedoms in the EC Treaty