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  • What the Mansworth v Jelley case means
    The UK Inland Revenue's interpretation of the decision in the case of Mansworth v Jelley (2003, STC 53) caused much debate last year in the UK as the Inland Revenue surprisingly accepted the decision, even though it was against them, rather than appealing further. Although they subsequently changed their legislation to neutralize the impact of their interpretation of the decision, the ruling could still have an impact in Ireland as the country has similar legislation to that of the UK before this amendment.
    December 01 2004
  • marksspencer-dec04jan05.jpg
    Dorsey & Whitney reshuffles before ECJ tax cases
    As the UK High Court is about to give details of its referral of a thin-capitalization group litigation order to the European Court of Justice (ECJ), Philip Martin, formerly deputy head of tax at retailer Marks & Spencer, has abruptly left Dorsey & Whitney, the US law firm handling the order for claimants including Pepsi, Volvo and a subsidiary of Caterpillar.
    December 01 2004
  • Hong Kong government proposes capital gains tax
    The introduction of a capital gains tax (CGT) in Hong Kong would be deeply unpopular according to members of the tax community there. Henry Tang, Hong Kong's finance secretary has proposed the introduction of a CGT to increase tax revenues, reduce Hong Kong's spiralling fiscal deficit and broaden the tax base.
    December 01 2004
  • shell-dec04jan05.jpg
    Shell merger raises dividend tax issues
    The Royal Dutch/Shell group's share-swap merger of its twin holding companies has required the Dutch tax authorities to approve a unique dividend access mechanism so that shareholders in the UK and in the Netherlands retain their present entitlements.
    December 01 2004
  • Brazil to shorten tax filing deadlines
    From January 1 2005 large companies with operations in Brazil will have to meet monthly instead of quarterly deadlines for filing their federal tax and contributions return. Brazil's Federal Revenue Department, announced on December 2 2004 that companies with annual gross revenues more than BRL80 million ($29 million) will be affected by the changes.
    December 01 2004
  • New Zealand targets banks with thin-capitalization changes
    Banks with operations in New Zealand face higher tax burdens after the government introduced a bill in November to radically tighten the country's thin-capitalization rules for the banking industry, which has been accused of paying too little tax.
    December 01 2004
  • durst-dec04jan05.jpg
    PwC rehires transfer-pricing specialist
    Michael Durst: Wants a strong global network Michael Durst, formerly of the US law firm King & Spalding, has rejoined PricewaterhouseCoopers' transfer-pricing practice. In his new position, Durst is advising clients in tax dispute resolution, international tax planning and controversy defence.
    December 01 2004
  • Haarmann Hemmelrath boosts German tax practice
    The Frankfurt tax practice of German law firm Haarmann Hemmelrath will be strengthened in January 2005 with the arrival of Joachim Krämer and Roderic Pagel, two international tax partners.
    December 01 2004
  • EU Savings Directive provisional guidelines released
    On October 19 2004 the Swiss Federal Tax Administration published a draft of the guidelines of the agreement between the European Union and Switzerland regarding taxation of savings income in the form of interest payments (commonly known as the Savings Directive).
    December 01 2004
  • usjobs-diag1-dec04.gif
    What you should know about the Jobs Act
    Foreign multinationals should examine the recent corporate tax reform carefully for any impact on their US investments, warn PwC advisers in New York and Washington, DC
    December 01 2004
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