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Tax Executives' Institute criticizes OECD permanent establishment guidelines

The Tax Executives Institute (TEI) has criticized the OECD's revised discussion draft on new guidelines for the attribution of profits to permanent establishments. In a letter to Jeffrey Owens, director of the centre for tax policy and administration at the OECD in Paris, Judith Zelisko, the TEI's international president, said the latest draft could increase the risk of double taxation and the number of tax disputes.

November 01 2004

Venezuela raises taxes on foreign oil companies

Hugo Chavez, Venezuela's president, announced a sharp rise in the royalty tax on multinational oil companies on October 10 2004. The tax increase from 1% to 16.6% per barrel of oil was effective immediately and affects all foreign oil companies operating in the southwestern Orinoco region of Venezuela. The rate rise is expected to raise an annual $1.27 billion in additional tax revenues.

November 01 2004

India's multi-functional transfer pricing fails to add up

By Shanto Ghosh, Deloitte and Sumon Mazumdar, LECG

November 01 2004

Government overhauls withholding tax exemption system

The procedures for withholding tax exemption on Japan source income received by foreign corporations and non-residents in Japan have been changed from the "submitting method (teishutsu)" to "presenting method (teiji)".

November 01 2004

Commission deems tax incentive to be illegitimate State aid

The Official Journal of the European Union of September 9 2004 contained the European Commission's invitation to submit comments to its letter to the Italian Government of May 7 2004 where it claimed that a certain Italian tax incentive should be treated as an illegitimate State aid pursuant to articles 87 and following of the EU Treaty.

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

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. Certain changes to the rules affecting income trust structures featured prominently in the Budget. The September 16 2004 draft Budget legislation contains some important changes from the measures announced in the Budget.

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

New tax incentives

On September 6 2004 Law 25.924 introduced a transitory regime aimed at promoting investments in industrial activities and infrastructure during the next three years.

November 01 2004

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