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  • Special focus: Switzerland
    Bruno Schefer, of Züblin Immobilien, speaks to Ralph Cunningham about how the commercial property investment company uses outsourcing to deal with its tax affairs In separate articles, PricewaterhouseCoopers and KPMG analyze significant recent changes concerning VAT, transfer pricing, restructuring and M&A and highlight what taxpayers can expect in the future
    March 01 2005
  • Tax structuring is key to private equity success
    Putting together tax-effective private equity transactions in Europe can be complex. Some methods have been shown to work, explains Lars Jonsson of Linklaters
    March 01 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
  • What the 2005 reforms will mean
    Austria's landmark tax reform 2005 came into effect on January 1 2005. Introduced by the Tax Reform Act 2005 (Steuerreformgesetz 2005) and the Tax Amendment Act 2004 (Abgabenänd-erungsgesetz 2004), the tax reform 2005 has brought major changes in Austria's corporate income tax system and aims to increase the country's international competitiveness.
    March 01 2005
  • Authorities press for offshore disclosure
    The Inland Revenue believes that the scope of tax legislation relating to offshore trusts is extraterritorial. Aileen Barry of DLA Piper Rudnick Gray Cary examines the basis of the claim and the action that should be taken
    March 01 2005
  • Why Australia needs more tax reform
    By John Stanhope, Business Coalition for Tax Reform
    March 01 2005
  • Tax authorities clear up commissionaire structures
    With Ruling 12/E dated February 1 2005 (the Ruling), the Italian Tax Authorities (ITA) have given their interpretation on the application of the anti-abusive rule set out in articles 110(10) and 110(11) of Presidential Decree 917 of December 22 1986 (the Italian Income Tax Code or ITC), in the context of a commissionaire agreement.
    March 01 2005
  • Europe debates real estate investment trusts
    Cristina Arumi and Jonathan Ivinson of Hogan & Hartson analyze the US REIT regime in the context of proposals for similar vehicles in the UK and Germany
    March 01 2005
  • Judges highlight legal advice privilege
    Legal privilege protection, the general anti-avoidance provision and permanent establishment under tax treaties featured in some of the more interesting tax litigation in Australia over the past 12 months, reveals Kevin Pose of Allens Arthur Robinson
    March 01 2005
  • Bush's tax reform panel asks for input
    The panel's brief President Bush set up the bipartisan panel in January with a brief to deliver a report to the secretary of the Treasury with revenue-neutral policy options that:
    March 01 2005
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