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  • 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
  • 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
  • New Zealand targets banks with thin-capitalization changes
    Banks with operations in New Zealand face higher tax burdens after the government introduced a bill on November 16 2004 to radically tighten the country’s thin-capitalization rules for the banking industry, which has been accused of paying too little tax
    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
  • Omani update: New income tax law proposed in Oman
    The Ministry of National Economy is working on a new income tax law to replace the current legislation, originally issued in 1981
    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
  • 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
  • Tax reform debate gains momentum in the US
    Abolishing the Internal Revenue Service and replacing taxes on income and investment with a flat national sales tax on consumption are some of the radical ideas gaining support in Washington, DC
    November 21 2004
  • US inbound update: Reorganization ruling has international ramifications
    Revenue Ruling 2004-83 holds that the sale of one subsidiary to another subsidiary followed by the liquidation of the purchased subsidiary as part of an integrated plan qualifies as a reorganization under Internal Revenue Code (IRC) section 368(a)(1)(D) and is not subject to IRC section 304, whether or not the subsidiaries are part of a consolidated group
    November 21 2004
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