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How to structure corporate acquisitions

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.

June 30 2005

Whether the taxation of foreign dividends is compatible with EU law

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.

June 30 2005

MFN concept threatens tax treaty network

Michel Guilluy, Eric Centi and Vincent Marquis of PricewaterhouseCoopers, examines the interaction between the MFN clause and the fundamental freedoms in the EC Treaty

June 30 2005

EU makes progress on cross-border mergers

The tax and legal rulebook to facilitate cross-border mergers of companies within the EU is expanding all the time. However, Germany is one member state which still requires domestic implementation legislation, explains Jürgen Hartmann

June 30 2005

Circular confirms profit repatriation rules

Belgium's tax authorities have issued guidance on how they shall interpret the country's tax treaty with Hong Kong. The guidance discusses Hong Kong profit repatriation to Belgium, explain Kurt De Haen and Guy Ellis of PricewaterhouseCoopers

June 30 2005

How to avoid stamp duty horrors on debt deals

It is important how you classify the debt in a debt transaction in the UK. You need to structure your arrangements properly so that the debt is exempt loan capital and no stamp duty is payable, explain Ian Johnson and Paul Miller of Ashurst

June 30 2005

Wijn spells out Netherlands tax reforms

In an interview with International Tax Review, the minister in charge of the Dutch tax system, outlines government reforms to protect and increase corporate tax revenues

June 30 2005

Seven steps to managing your VAT successfully

Global VAT obligations can overwhelm a company with no system to deal with them. Some careful planning can help companies to cope, argues Chris Walsh of Vertex

June 30 2005

NBC deal ends Vivendi Universal's tax dispute

NBC IAC/Interactive, an internet company, has sold its stake in Vivendi Universal Entertainment (VUE) to NBC Universal for $3.4 billion, ending a $620 million dispute over taxes on IAC's preferred stock in VUE.

June 30 2005

Danish business attacks transfer pricing changes

The tax director of one of Denmark's most famous multinational companies has labelled the country's new domestic transfer-pricing regime, which requires affiliated companies to document domestic transactions for tax purposes, "foolish and unnecessary".

June 30 2005

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