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  • Getting the most out of the double tax treaty with Cyprus
    Under the double tax treaty with Cyprus, investors can enjoy a 5% withholding tax rate on dividends distributed by a Russian subsidiary, rather than the regular 15% rate. Therefore, using Cypriot holding companies is one of the most typical vehicles to structure inbound investments in Russia.
    May 04 2005
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    China presses ahead with corporate tax reform
    Brendan Kelly: Tax reforms must be accompanied by a clampdown on tax avoidance Foreign companies in China are set to lose their preferential tax rate after a state official said that the process of equalizing tax treatment for foreign and domestic companies is "highly likely" to begin this year.
    May 04 2005
  • Why it is important to correctly characterize services
    Changes to the definition of "business activities" in the income tax law have tax implications for the characterization of services. The Mexican tax implications of income received by a foreign parent company for the rendering of services has always depended on the underlying nature of the service being rendered.
    May 04 2005
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    M&S opinion keeps Europe guessing
    The opinion of the advocate-general in the Marks & Spencer (M&S) case at the European Court of Justice (ECJ) backs up the UK retailer's argument for cross-border group relief within the EU. But confusion remains about how the opinion will shape the final judgment and how national governments will react. Ralph Cunningham and Simon Briault investigate
    May 04 2005
  • A new tax credit for training expenses
    Anew tax system for training expenses was introduced on April 1. The new system allows a corporation to credit the amount of training expenditure against its corporate tax. The limitation of the credit is 10% of the corporate tax.
    May 04 2005
  • Advocate general rules regional tax contravenes VAT Directive
    An advocate general opinion of the European Court of Justice (ECJ) exposes inconsistencies between the regional tax on productive activities (IRAP) and the VAT Directive.
    May 04 2005
  • Structured finance vehicles and IFRS
    In recent years Ireland has become an increasingly popular jurisdiction for the establishment of special purpose vehicles (SPVs) for securitization, repackaging, collateralized debt obligations (CDOs), warehousing and other structured finance transactions.
    May 04 2005
  • When tax on dividends conflicts with EU law
    Elements of Germany's taxation of dividends under the old corporation tax law may fail to pass EU requirements.
    May 04 2005
  • New estate planning rules
    Belgium is already known as an attractive region for estate planning but new rules make it even more attractive. Movable property given "from hand to hand" was already exempted from gift tax. However, if the donor dies within three years from the date of such gift, the gift is deemed to be a legacy and will be subject to inheritance tax (at the progressive rates).
    May 04 2005
  • Tax implications of the IFRS
    The application of the international financial reporting standards (IFRS) in Australia has a number of tax implications.
    May 04 2005
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