ITR Search | International Tax Review

Proper structuring is essential to holding company success

Taxpayers need to be aware that the environment for holding companies in Germany is changing constantly, warn Franz Prinz zu Hohenlohe and Stephan Behnes of KPMG

December 20 2004

Tackling the tax future

Bernd Jonas, of ThyssenKrupp, talks to Ralph Cunningham about the challenges facing tax executives in Germany and what the government should be doing to help business

December 20 2004

Guidance reassures M&A investors

The German M&A tax environment has been the subject of some legislative change in the recent past. Any transactions require careful planning, point out Christian Ehlermann, Manfred Guenkel and Christoph Röper of Deloitte

December 20 2004

Finance ministry unveils more transfer-pricing regulation

Germany has published a draft decree dealing with the administrative procedures of transfer pricing. More guidance is likely at a national and EU level, point out Dieter Endres, Andrew Miles and Andreas Oestreicher of PricewaterhouseCoopers

December 20 2004

Stichting ‘Goed Wonen’ v Staatssecretaris van Financiën

VAT – Sixth Directive 77/388/EEC – Legal certainty – Legitimate expectations – Amendment of national law – Grant of a usufructuary right – Transaction previously subject to tax – Exemption – Application with retroactive effect – Compatibility.

December 16 2004

António Jorge Lda v Fazenda Pública

Value added tax – Deduction of input tax – Real property transactions – Goods and services used for taxable and non-taxable transactions – Deductible proportion – Services not completed and not paid for.

December 16 2004

Commission v United Kingdom

Failure of a member state to fulfil obligations – Articles 17(2)(a) and 18(1)(a) of the Sixth VAT Directive 77/388/EEC – National provision under which an employer is allowed to deduct input tax in relation to his reimbursements of his employees’ road fuel costs.

December 14 2004

Canadian update: Good news for back-to-back cross-border loans

The Canada Revenue Agency (CRA) has issued a series of favourable tax rulings in which it concluded that Canadian domestic anti-avoidance legislation would not apply to certain proposed transactions involving back-to-back cross-border loans

December 12 2004

Blake Dawson Waldron hires Deloitte tax partner

Duncan Baxter, a former senior partner at Deloitte in Australia has left the big four firm to join Blake Dawson Waldron (BDW), the international law firm. Baxter, who specializes in corporate and international tax, will lead BDW’s direct tax practice in Melbourne

December 12 2004

UK government reviews tax authority powers

The UK government has announced a wide-ranging review of the powers of the country’s tax authorities ahead of the merger in 2005 between Customs & Excise and the Inland Revenue to create HM Revenue and Customs (HMRC)

December 12 2004

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