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  • Analysis Group
    March 31 2005
  • Alston & Bird LLP
    March 31 2005
  • Tax tribunal considers withholding tax issues for software
    The National Tax Tribunal issued a noteworthy comment on the withholding tax treatment of a payment for software developed by a foreign company and distributed by a Japanese company. The tribunal case discusses payments for software products from the Japanese distribution company to the foreign company by classifying them into the following three types. It should be noted that the classification of the software transactions should be determined based on the facts and substance rather than contract terms.
    March 31 2005
  • ECJ decision and opinion favour the taxpayer
    The European Court of Justice (ECJ) held on March 10 2005 that limiting the French tax credit for research expenditure to research carried out in France violates the free movement of services principle of article 59 EC (Case C-39/04 Laboratoires Fournier). Several other EU countries still maintain rules similar to those struck down by the ECJ.
    March 31 2005
  • Notional interest deduction on the right track
    The introduction of the so-called notional interest deduction (as announced in the February edition) is on the right track. On March 4 2005, it was approved by the Belgian Council of Ministers and, as a result, the draft law is expected to be voted on in June 2005.
    March 31 2005
  • Exit tax regime catches up with Europe
    The Tax Amendment Act 2004 (Abgabenänderungsgesetz) has brought about considerable changes in Austria's exit taxation regime. Such changes implement EU legislation on the European Company (SE) and reflect the decision of the European Court of Justice (EU) in the de Lasteyrie du Saillant case (C-9/02).
    March 31 2005
  • Transfer pricing audits become more frequent
    The Australian Taxation Office's (ATO) concern that multinationals are continually shifting profits has led to increased scrutiny of transfer pricing practices. In particular, the ATO has a renewed focus of the Transfer Pricing Review Project, which deals with:
    March 31 2005
  • 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
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