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  • 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
  • Ireland's holding company regime is legal
    The European Commission has approved Ireland's holding company regime, which provides for a tax exemption on chargeable gains arising from the disposal of shares, or assets related to those shares, in some subsidiaries. The regime is part of a package of measures designed to increase Ireland's attractiveness as a holding company location.
    September 30 2004
  • Tax breaks for UK film industry get cool response
    The UK Treasury on September 21 2004 introduced a new package of tax breaks for the film industry, replacing the so-called section 48 incentives. The UK government decided to amend the scheme after a crackdown in February on partnership schemes (often used to fund UK films) that manipulated tax relief to create claims for losses in excess of the capital at risk.
    September 30 2004
  • Thin-capitalization amendments affect financing arrangements
    Domestic companies are now subject to thin-capitalization rules in Germany. Taxpayers should examine each structure before deciding whether to take steps to comply with the changes, urge Ralph Dautel, Jochen Murach and Alexander Pupeter of P+P Pöllath + Partners
    September 30 2004
  • UK and Indian companies to benefit from changes to tax dispute procedures
    India's Central Board of Direct Taxes (CBDT) has issued an instruction that will benefit Indian and UK taxpayers involved in tax disputes under the two countries' double taxation agreement (DTA).
    September 30 2004
  • korb-julaug04.jpg
    Korb promotes US APA process in Europe
    Donald Korb: Handling transfer pricing
    September 30 2004
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    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
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