ITR Search | International Tax Review

I/S Fini H v Skatteministeriet

Sixth VAT Directive – Status of taxable person – Right to deduct – Winding up – Direct and immediate link – Transactions forming part of the economic activity as a whole.

March 03 2005

The legislature and Federal Court send mixed signals on M&A

New merger legislation clarifies corporate and tax law and has improved Switzerland's appeal as a business location, point out Peter Uebelhart, Michel Jaggi and Jean-David Wenger of KPMG

March 02 2005

Getting the tax right

The right tax structure is essential to commercial property deals. Bruno Schefer, chief executive officer of the Swiss property investor, Züblin Immobilien, tells Ralph Cunningham how his company obtains and uses the best tax advice

March 02 2005

Restructuring and VAT: Mind the traps

Taxpayers must pay attention to value-added tax issues when dealing with restructurings in Switzerland, warn Michaela Merz and Tobias Meier Kern of PricewaterhouseCoopers

March 02 2005

Switzerland maintains key position in transfer-pricing

Transfer pricing is central to the realization of defensible, efficient business models, value-chain designs, and corporate-tax optimization planning, as well as opportunities for M&A, argues Norbert Raschle of PricewaterhouseCoopers

March 02 2005

Amendments to corporate tax system lack breadth

A second round of corporate tax reform is on the way. Current proposals are of limited scope, points out Marcel Widrig of PricewaterhouseCoopers

March 02 2005

ECJ to revisit the old thin-capitalization rules

In December 2002 the European Court of Justice (ECJ) held that the German thin-capitalization rules (section 8a Corporate Income Tax Law or CITL) as in force through 2003 (old thin-capitalization rules) violated the freedom-of-establishment clause of the European Community Treaty (article 43 EC Treaty) when applied to shareholders resident in EU member states. As a result, the German government enacted new thin-capitalization rules for fiscal years beginning after December 31 2003.

March 01 2005

Three-year transition announced for IFRS and thin capitalization

The International Financial Reporting Standards (IFRS) came into effect in Australia on January 1 2005. It was clear some time ago that these new accounting standards would impact directly on Australia's thin-capitalization rules, which seek to limit interest expense deductions for certain taxpayers that exceed certain debt-to-asset ratios. This is because the thin-capitalization safe harbour calculation is made with reference to accounts prepared in accordance with Australian accounting standards.

March 01 2005

Directive transforms collateral rules

The implementation of the EU Collateral Directive in Belgium has exposed its inefficiencies, point out Koen Vanderheyden and Julie Gabriel, of Lawfort

March 01 2005

Venezuela closes Coca-Cola and McDonald's outlets over tax records

Venezuela's campaign against corporate tax irregularities has got tougher. The country's tax authorities (Seniat) closed down Coca-Cola Femsa distribution and bottling centres, just a week after closing down all of McDonald's fast-food restaurants in the country for three days.

March 01 2005

Search results for