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  • Tax treaty signifies new start for Japanese transfer pricing
    Issues concerning transfer-pricing methodology in the Japan-US Tax Treaty should have a significant effect on audits and the advance pricing agreement process, believes Kazuo Taguchi, of Baker & McKenzie
    March 31 2005
  • OECD fails to deliver stock option certainty
    In 2004 the OECD released a study on transfer pricing issues arising from employee stock option plans. Gareth Green of Transfer Pricing Solutions, William Franklin of Pinsent Masons and Mike Heimert of Ceteris consider what can be learned from it
    March 31 2005
  • A long way to go for thin capitalization rules
    Important differences in the tax treatment of equity and debt show that the new Mexican thin-capitalization rules are incomplete, argue Roberto Del Toro, John Salerno and Lisette Tautfest of PricewaterhouseCoopers
    March 31 2005
  • KPMG puts focus on Irish tax advice
    KPMG, an accounting, tax and advisory firm, has set up an Ireland Tax Centre of Excellence to help US companies with operations in Ireland and those that are thinking of setting up a base there. The centre of excellence will also provide tax services to Irish companies that have invested in the US.
    March 31 2005
  • Dubert returns to PwC after Treasury stint
    The US Treasury's former deputy international tax counsel has moved to private practice after a two-and-a-half-year stint in government.
    March 31 2005
  • Altria hires Nestle's international tax counsel
    Fabio De Angelis has moved to Altria as senior European tax counsel, where he will be responsible for Eastern Europe, the Middle East and Africa and the company's duty free business worldwide. For the last five years he has been international tax counsel for Nestle. De Angelis is the current president of the European chapter of the Tax Executives' Institute.
    March 31 2005
  • Taxpayer victory on double tax relief conundrum
    The main issue in dispute between the taxpayer company, a life assurance company, and the Inland Revenue, was how double tax relief is calculated where the receipt that has been subject to overseas tax is included in trading profits taxed on schedule D-case I principles.
    March 31 2005
  • New anti-fronting law released
    The government released a new anti-fronting law for the UAE in late 2004. It is intended that this law will come into force in 2007 and, should it do so, it is likely to change how business is done in the UAE.
    March 31 2005
  • What the tax overhaul will mean
    Corporates can expect some far-reaching changes in the tax arena in Spain. Among the initiatives recently announced, which will be embodied in legislative changes in the short term, reference may be made to the approval by the Council of Ministers on February 25 2005 of the first package of measures of the Plan for the Dynamization of the Economy.
    March 31 2005
  • New incentives for service centres in special economic zones
    There has been significant change in Polish legislation on special economic zones (SEZs) that substantially increase their attractiveness to multinational investors.
    March 31 2005
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