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Lawyers agree on new tax disclosure rules

The UK’s tax disclosure burden shifted to clients last week after The Law Society reached an agreement with the Inland Revenue on the issue of legal professional privilege (LPP)

October 09 2004

US inbound update: Proposed reorganization regulations make planning mergers even easier

It is common for acquisitions to be conducted in the US on a tax-free basis through stock-for-stock exchanges

October 09 2004

Swiss update: New benefits under the EU Directives

On July 19 2004 the EU Council formally adopted the decision of the European Commission to delay implementation of the EU Savings Directive from January 1 2005 until July 1 2005

October 09 2004

Netherlands clarifies tax-loss rules for 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

October 09 2004

Italian update: New international ruling procedure becomes effective

On July 23 2004 the Italian central tax agency issued the explanatory notes (the Explanatory Notes) envisaged by article 8(2) of Law Decree 269, of September 30 2003 (Decree 269) necessary to allow certain enterprises that carry on an international activity (each an International Enterprise) to apply for the ad-hoc ruling procedure (the International Ruling Procedure) established by article 8 of same Decree 269

October 09 2004

Korb promotes US APA process in Europe

Donald Korb, the US Internal Revenue Service (IRS) chief counsel, used his keynote address at International Tax Review’s fourth Global Transfer Pricing Forum in Berlin on September 29 2004 to promote the benefits of the US’ advance pricing agreement (APA) programme

October 02 2004

Garlick to run UK’s large business tax group

David Garlick has been appointed as head of the large business service in the UK’s new HM Revenue and Customs (HMRC)

October 02 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)

October 02 2004

EU update: ECJ facilitates acquisitions of Belgian target companies

According to the Belgian income tax code, the taxation of capital gains realized by individuals as substantial shareholders on the sale of shares in Belgian companies depends on the residence of the acquirer

October 02 2004

Australian update: The focus of the new compliance programme

The recently-released 2004-05 Compliance Program for the Australian Tax Office (ATO) sounded a warning bell for companies, which will face aggressive compliance activity by the ATO in the coming year

October 02 2004

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