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  • Barclays hires new group head of tax to start in 2005
    Heather Devine, head of UK and cross-border taxation at Hanson, the multinational concrete producer, will join Barclays as group tax director in January 2005.
    November 01 2004
  • IRS says Societas Europaea is per se corporation
    The Internal Revenue Service (IRS) has issued Notice 2004-68 adding several European business entities to the list of per se corporations.
    November 01 2004
  • India resolves taxation of business process outsourcing
    India's Central Board of Direct Taxes (CBDT) has released a circular to dispel the long-running confusion over the taxation of business process outsourcing (BPO). The September 28 2004 communication confirms that the CBDT will tax BPO units according to the country's transfer-pricing principles and India's extensive tax treaty network.
    November 01 2004
  • Fidal hires EY Law partner
    Hervé Bidaud, an international tax specialist at EY Law, has jumped ship to Fidal in France. Bidaud advises French companies and foreign investors on mergers, acquisitions and reorganizations. In addition to being part of Fidal's tax practice, he will work with Fidal's management to develop international advisory services for mid-market companies.
    November 01 2004
  • Netherlands clarifies tax-loss rules on fiscal unities
    The government of the Netherlands has clarified the rules on how fiscal unities should allocate tax losses to subsidiaries when they leave the group. Joop Wijn, the Dutch state secretary of finance, on October 1 2004 issued a decree that answers taxpayers' queries on the fiscal unity rules first introduced on January 1 2003.
    November 01 2004
  • Oman proposes new income tax law
    Oman's Ministry of National Economy is working on a new income tax law that would consolidate the existing legislation (originally issued in 1981), simplify tax procedures and speed up tax assessments. Interested parties have submitted recommendations on the interpretation of permanent establishments, transfer-pricing rules and the need for an official English version of the tax laws.
    November 01 2004
  • Germany revises international tax regulations
    In May 2004, the German Federal Ministry of Finance issued an updated and revised version of the comprehensive regulations that guide the tax authorities in their application of the Foreign Transactions Tax Law (Aussensteuergesetz - AStG). The revised regulations (published in the German Federal Gazette Part I 2004, special issue 1/2004) supersede those of December 1994 and reflect subsequent legislation and high court decisions.
    November 01 2004
  • Draft Finance Bill proposes new rules on company transfers
    The draft Finance Bill for 2005 provides for an amendment to the French Tax Code with respect to the tax consequences of the transfer by a French company of its registered office to another EU member state.
    November 01 2004
  • Ireland attracts HQs and holding companies
    As previously mentioned in this column in April 2004, the Irish Finance Bill 2004 contained a number of measures aimed at increasing the attractiveness of Ireland as a corporate headquarters and holding company (HoldCo) jurisdiction. Broadly these new measures provided for an exemption from corporation tax on gains arising on the disposal of qualifying shares, and a wider double tax relief for foreign taxes levied on dividends received by an Irish resident company.
    November 01 2004
  • Landmark international tax bill signed into law
    The American Jobs Creation Act is the most comprehensive corporate tax law in the US for almost 20 years. Taxpayers need to get to grips with what it means for their business, urge Margie Rollinson, Michael Mundaca and David Benson, of Ernst & Young
    November 01 2004
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