ITR Search | International Tax Review

Baker & McKenzie poaches Landwell tax partner

Pierre-Yves Bourtourault: VAT in the EU is still highly complex The French tax practice of Landwell, the PricewaterhouseCoopers-affiliated law firm, has lost a high profile value-added tax (VAT) partner to Baker & McKenzie. Thierry Vialaneix specializes in VAT advice for manufacturing, distribution, tourism, finance and media companies. He joined Baker & McKenzie's Paris office in November 2004.

December 01 2004

The scope of the revenue laws amendments

The Revenue Laws Amendment Acts was passed by parliament in November 2004. These are omnibus Acts that amend a number of different fiscal Acts of Parliament (relating to areas including income tax, value-added tax, stamp duty and customs duty).

December 01 2004

Deloitte reclaims top US Treasury official

The US tax system benefits from a healthy interchange of tax professionals between the Treasury and the IRS on the one hand and law and accounting firms on the other. Many tax specialists, such as Deborah Harrington, remain in government for three or four years before returning to private practice. Harrington returned to Deloitte on November 19 2004.

December 01 2004

How the new disclosure requirements for VAT planning work

Businesses are now required to make a disclosure to HM Customs & Excise when they derive a UK value-added tax (VAT) benefit from the use of certain VAT-planning arrangements. The VAT-avoidance disclosure rules came into force on August 1 2004 and the first disclosures were due by October 30 2004.

December 01 2004

What the tax reforms will mean

The original proposal sent to the Congress to amend the Income Tax Law has suffered some changes regarding thin-capitalization rules that would enter into force on January 1 2005.

December 01 2004

Kovacs confirmed as tax commissioner

Laszlo Kovacs: Advocates a common consolidated tax base for the EU The new EU commissioner for taxation and customs union is sticking to European Commission orthodoxy on corporate tax.

December 01 2004

Tax treatment of different business structures

There are various entity forms of doing business in foreign countries that exist between corporate form and the kumiai form. The Japanese tax treatment for each entity form is unclear. Especially regarding US limited liability corporations (US LLCs) and US limited partnerships (US LPs), there are no clear guidelines to help determine whether these entity forms are subject to corporate level taxation or pass-through taxation for purposes of Japanese taxes.

December 01 2004

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

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

EU forces changes to Denmark's transfer-pricing rules

Kristian Jensen, the Danish minister of taxation, has published draft legislation to tighten the country's transfer- pricing regime. The stringent proposals, intended to comply with the EU principle of freedom of establishment, would introduce documentation requirements for domestic as well as cross-border transactions.

December 01 2004

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