ITR Search | International Tax Review

Brazilian update: 0% withholding tax applies to extension of payment terms

On July 23 2004, provisional measure 183 was converted into Law 10,925

November 28 2004

McDermott Will & Emery reclaims PwC tax partner

Citing Sarbanes Oxley difficulties, tax partner Philip McCarty has left PricewaterhouseCoopers to rejoin, on November 8 2004, international law firm McDermott Will & Emery (MWE) in Washington, DC, where he worked until 2001

November 28 2004

OECD delays permanent establishment guidelines

Businesses waiting for guidance on the attribution of profits to permanent establishments will have to wait longer than expected after the OECD delayed the release of its report on the subject

November 28 2004

Hotel Scandic Gåsabäck AB v Riksskatteverket

Sixth VAT Directive – Chargeable event – Transactions regarded as supplies of goods and services for consideration – Provision of meals for its staff, at a price lower than cost price, by an undertaking operating in the hotel and restaurant sector – Interpretation of Articles 2, 5(6) and 6(2)(b).

November 23 2004

Fokus Bank ASA v The Norwegian State

Free movement of capital; taxation of dividends; tax credit granted exclusively to shareholders resident in a Contracting Party; denial of procedural rights to shareholders resident in other Contracting Parties;

November 23 2004

Deloitte reclaims top US Treasury official

Deborah Harrington, an attorney adviser in the US Treasury’s office of tax legislative counsel, has returned to the Washington, DC office of Deloitte, the big-four professional services firm

November 21 2004

Mexican update: Thin capitalization rules reach Congress

The tax authorities have sent the Congress a tax bill including proposed legislation concerning additional interest deductibility restriction to be effected through a series of thin capitalization rules that would enter into force on January 1 2005

November 21 2004

Spanish update: Spanish public companies must report on intra-group transactions

At the heart of discussions within the EU about excessive transfer-pricing documentation requirements being imposed on European multinational enterprises (MNEs), in recent times there has been an increase within the member states of reporting obligations set forth for regulatory purposes, which also include information among related parties

November 21 2004

Kovacs confirmed as tax commissioner

The new EU commissioner for taxation and customs union is sticking to European Commission orthodoxy on corporate tax

November 21 2004

Canadian update: Budget legislation tightens certain income fund proposals

Draft legislation was recently released by the Canadian Department of Finance to implement many of the measures announced in the government's March 23 2004 Budget

November 21 2004

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