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  • korb-julaug04.jpg
    Korb promotes US APA process in Europe
    Donald Korb: Handling transfer pricing
    September 30 2004
  • cussons-feb03.jpg
    Manninen is another blow for national tax
    The European Court of Justice (ECJ) struck out again at national tax systems throughout the EU on September 7 2004, when it ruled that a Finnish man was entitled to a tax credit under Finland's tax system on the dividend he received from a foreign company.
    September 30 2004
  • European Commission heads off future scandal with corporate tax strategy
    The European Commission has adopted a strategy on corporate tax compliance to head off future scandals involving financial malpractice. The strategy, which was released on September 30, calls for actions at the global level to foster company tax transparency and actions at the EU level to strengthen the work of tax administrators and to improve monitoring of companies.
    September 30 2004
  • 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. Assume that a European company (EuropeCo) lists its shares in the US and desires to acquire a US company (US Target) by providing a mix of EuropeCo shares and cash. Normally this can be done by EuropeCo forming a US acquisition vehicle (US Newco) and US Target mergers into US Newco, providing EuropeCo shares and cash to the former Target shareholders.
    September 30 2004
  • White & Case snaps up former Commerzbank tax specialist
    The German tax practice of US law firm White & Case hired Christoph Schröder, formerly a member of Commerzbank's corporate finance team, on September 15 2004. As a partner at White & Case, Schröder will advise on tax issues relating to capital markets products and company succession planning.
    September 30 2004
  • haddad-oct04.jpg
    Government continues reform of system of social taxes
    The PIS and COFINS taxes have been extended to include the importation of goods and services. Taxpayers need a detailed knowledge of where the new charges apply, warns Roberto Haddad of Branco Consultores
    September 30 2004
  • us-diag1-oct04.gif
    How to make transfer pricing work for IP and intangible assets
    Taxpayers must recognize the value of IP and use the correct valuation method for it, believe Weston Anson and Chaitali Ahya of Consor Intellectual Asset Management
    September 30 2004
  • IRS rejects tax lobby act
    The chief counsel of the Internal Revenue Service (IRS) in Washington, DC has disputed findings in a report from Citizens for Tax Justice (CTJ) and the Institute on Taxation and Economic Policy (ITEP) released in September 2004.
    September 30 2004
  • China publishes APA implementation rules
    The State Tax Administration of China released rules on September 20 2004 that implement the country's advanced pricing agreement (APA) programme. The rules resolve the ambiguity about the APA process and outline a uniform process to conclude APAs between taxpayers and local tax authorities throughout China.
    September 30 2004
  • India gives its final word on the taxation of business process outsourcing
    India's Central Board of Direct Taxes (CBDT) has released a final circular to dispel the long-running confusion over the taxation of business process outsourcing (BPO). The September 28 2004 communication circular confirms that the CBDT will tax BPO units according to the country's transfer- pricing principles and in accordance with India's tax treaty network.
    September 30 2004
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