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Australian update: International taskforce targets package schemes

In recent years, eliminating abusive tax schemes has risen to the top of the agenda for revenue authorities, both locally and internationally

September 18 2004

Indian update: Advance ruling on liaison offices

A recent Indian authority advance ruling (AAR) examined whether a liaison office (LO) of a foreign company constituted a permanent establishment (PE) in India

September 18 2004

French update: The Hallminster case and the UK treaty

In the Hallminster decision (Case 250328), rendered on February 25 2004, the French Supreme Administrative Court had to decide whether a capital gain realized by a company resident in the UK from the sale of a majority shareholding in a civil company running a vineyard in France was subject to tax in France

September 18 2004

Baker & McKenzie expands UK tax practice

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

September 18 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 18 2004

Sarkozy continues attack on low corporate tax rates

French finance minister Nicolas Sarkozy vowed on September 16 2004 to continue his efforts to penalize EU member states that have corporate income tax rates below the EU average. Sarkozy plans to write to all 24 of his fellow EU finance ministers to insist that EU countries rich enough to reduce taxes should not expect structural funds from the EU.

September 18 2004

Cimber Air A/S v Skatteministeriet

Sixth VAT Directive – Article 15(6), (7) and (9) – Exemption of exports outside the Community – Meaning of ‘aircraft used by airlines operating chiefly on international routes’ – Exemption for fuelling and provisioning of domestic flights.

September 15 2004

EU update: Imputation tax credits challenged before the ECJ

The European Court of Justice (ECJ) is likely to hold that shareholder relief on dividends in the form of an imputation tax credit is incompatible with the free-movement-of-capital principle under articles 56 and 58 of the EC Treaty

September 11 2004

Argentine update: What the new transfer pricing and thin- capitalization rules mean

The Argentine executive issued Decree No 916/2004 on July 23 2004, which provides clarification and new regulations to the provisions of last year's income tax reform introduced by Law 25.784

September 11 2004

German update: Thin capitalization rules finalized

Germany put new thin-capitalization rules into effect this year that are intended to conform to the requirements of European law

September 11 2004

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