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  • 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
  • Debt financing loses appeal as tax planning strategy
    The impact of legislative changes, the future of debt pushdown planning and a straightforward methodology for strategic tax planning are considered by Nick Woodford and Christoph Schreiber of PricewaterhouseCoopers. This article was written before the announcement of new rules in the UK Budget on March 16 2005.
    March 31 2005
  • Government plays safe with budget measures
    Anti-avoidance and Europe dominated the discussion of international tax matters after the UK Budget. Tax advisers explain to Ralph Cunningham what the government's plans mean for their clients
    March 31 2005
  • O2 releases new VAT compliance software
    Helen Wylde: thinks the revenue authorities are looking at VAT on mobile calls O2, a UK mobile phone operator, has released new software that separates business and personal mobile calls, helping tax directors comply with value-added tax (VAT) requirements.
    March 31 2005
  • Appeal likely in Samsung India's shrink-wrap software case
    Mukesh Bhutani: victory bodes well for similar cases Samsung, a Korean electronics company, has won a victory before a Bangalore tax tribunal on the tax implications of shrink-wrap software imports.
    March 31 2005
  • European court dilutes insurance VAT exemption
    The European Court of Justice (ECJ) has dealt a blow to outsourcers in the insurance industry with its judgement in the Dutch case of Staatssecretaris van Financien v Arthur Andersen & Co Accountants C S on March 3 2005.
    March 31 2005
  • EU disallows Italian tax breaks for newly-listed companies
    The European Commission on March 16 2005 said that Italian tax incentives that reduce the corporate tax rates of companies listed for the first time on a regulated EU stock exchange violate state aid rules. The disallowed incentive allowed companies that met certain conditions to receive a reduced 20% corporate tax rate (instead of the ordinary 33%) for the fiscal year in which the listing occurs, and the following two fiscal years.
    March 31 2005
  • Ernst & Young
    March 31 2005
  • Analysis Group
    March 31 2005
  • Canadian firm starts a transfer pricing practice
    Cole & Partners, a Canadian business valuation and financial litigation firm, has started a transfer-pricing practice with the hire of David Kemp from KPMG. Kemp has 13 years' experience advising multinational enterprises on transfer-pricing planning, documentation and dispute resolution.
    March 31 2005
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