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  • 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
  • Coudert Brothers adds French tax partner
    Yann de Kergos, a former partner at Ernst & Young, joined the international law firm Coudert Brothers on September 14 2004. Yann de Kergos, who brought two tax attorneys from his team at Ernst & Young, will lead the firm's Paris tax practice.
    September 30 2004
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    Baker & McKenzie expands UK tax practice
    James macLachlan: Law firms are getting more tax work John Fairley, a former senior international tax partner at Ernst & Young, has joined Baker & McKenzie, the US global law firm, as a senior consultant in London. Fairley is also a former UK Inland Revenue employee.
    September 30 2004
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    Revised decrees clarify APA rules
    The Netherlands has updated its APA rules. Dave Rutges, Eduard Sporken and Kelly Bouman of KPMG Meijburg & Co discuss what this will mean for corporate taxpayers
    September 30 2004
  • Cuatrecasas hires tax group in Portugal
    Independence and scope-of-service issues have helped another European law firm to hire tax practitioners from a big-four firm.
    September 30 2004
  • When agent residence constitutes a permanent establishment
    Recently in Sutron Corporation (268 ITR 156), Indian advance ruling authority (AAR) examined the issue of whether the presence of a country manager in India constitutes a place of business and hence a permanent establishment (PE) of a company. In this case, a US company entered into a contract with the Government of Andhra Pradesh (GAP) in India, under which it was required to supply goods for erecting remote stations and also to provide local materials and services.
    September 30 2004
  • The focus of the new compliance programme
    The recently-released 2004-05 Compliance Program of the Australian Tax Office (ATO) sounded a warning bell for companies, which will face aggressive compliance activity by the ATO in the coming year. While this is not big news for large companies - to which the ATO took their audit stick last year - small-and-medium-sized enterprises (SMEs) should prepare to face harsher scrutiny.
    September 30 2004
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    New EU members reject criticism of corporate tax rates
    The EU's newest members have reacted angrily to criticism from Nicolas Sarkozy, France's finance minister, that their low corporate tax rates are unfair. Sarkozy has claimed that the EU's 10 new members' states low corporate taxes are unfairly drawing jobs and investment away from older EU members.
    September 30 2004
  • Tax regime compensates for the end of offshoring
    Hungary's favourable tax regime for offshore companies ends in 2005. But the country's tax system will still be attractive to international business, believe Jacques de Servigny and Orsolya Bárdosi of Gide Loyrette Nouel
    September 30 2004
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    Government tries for more investment with corporate tax changes
    Austria's corporate tax reforms introduce wide-ranging changes, including a tax rate reduction, explain Christian Hoenig and Niklas Schmidt of Wolf Theiss
    September 30 2004
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