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  • What Marks & Spencer means for Irish taxpayers
    Marks & Spencer (M&S), a UK retailer, invoked articles 43 and 48 of the EC Treaty in an effort to use the losses generated by its subsidiaries in Belgium, Germany and France against its UK profits. In the ordinary course of events, M&S might have used these losses against profits generated by the subsidiaries in the relevant jurisdiction but M&S ceased trading in Belgium, Germany and France, leaving the subsidiaries awash with carry forward losses that were effectively useless or only partially useful.
    May 25 2005
  • Tax treaty network expands and holding company window to close
    After Israel, the tax treaty with Turkey has recently published and will enter into force on January 1 2006. The treaty is largely based on the OECD model.
    May 25 2005
  • How the Savings Directive works in Italy
    Italy has implemented Council Directive 2003/48/EC of June 3 2003 on taxation of savings income in the form of interest payments (the Directive) with Legislative Decree of April 18 2005, not yet published in the Italian Official Gazette as of May 16 2005 (the Decree).
    May 25 2005
  • When international tax clashes with EU law
    On April 28 2005 in Brussels the Confédération Fiscale Européenne held a forum entitled Tax Treaty for Europe? During a discussion at this forum the need was reiterated for EU law to take into consideration these international tax principles and not to ignore all the effort that was put into establishing all those principles.
    May 25 2005
  • What the new tax relief package would mean
    To stimulate the lethargic economy, the German government approved draft income tax relief legislation on May 4 2005. Unless otherwise stated, all measures would take effect in 2006 (fiscal year 2005/06 for non-calendar-year taxpayers).
    May 25 2005
  • Taxpayer council releases new transfer pricing decisions
    The Taxpayer's Council issued, in April 2005, three more decisions in favour of pharmaceutical companies regarding the application of the Brazilian transfer pricing methods.
    May 25 2005
  • Key points from the 2005 Budget
    On Tuesday, May 10, the federal treasurer Peter Costello delivered his tenth Budget.
    May 25 2005
  • New bill tries to reinforce anti-evasion rules
    Congress is about to pass a new bill that includes a series of reforms to the Tax Procedure Law, which allegedly aim at enhancing the fight against tax evasion in Argentina. The bill follows on the back of the initiatives launched in late 2003.
    May 25 2005
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    Ernst & Young
    May 25 2005
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    Structuring UK securitizations
    Recent experience shows that now is the correct time to put the taxation position of UK securitization companies beyond doubt, while addressing the concerns of the industry that the UK market should remain competitive, argues Martin Shah of Simmons & Simmons
    May 25 2005
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