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  • New tax framework comes into force
    A new Ley General Tributaria (General Taxation Law) was published on December 17 2003 (Law 58/2003). It came into force on July 1 2004. This new law abolishes the General Taxation Law in force since 1963 (amended in 1989, 1995 and 1998).
    August 31 2004
  • Scottish firm expands in London
    Dundas & Wilson, the Scottish law firm, has expanded its tax practice south of the border with the hire of Jim Hillan from Tite & Lewis in London. Hillan specializes in corporate and real estate tax and has practised at both Clifford Chance and Ernst & Young.
    August 31 2004
  • New real estate investment corporation amendments
    Pursuant to the 2004 tax law amendments, a real estate investment corporation (J-REIT) can hold 100% of the preferred investment certificates issued by a Tokutei Mokuteki Kaisha (TMK). Previously this was not allowed, because such an investment would not meet with one of the requirements for dividends distribution deduction.
    August 31 2004
  • Grant Thornton grabs PwCs tax partner
    Roger Burrows, a former partner at PricewaterhouseCoopers specializing in value-added tax (VAT), joined Grant Thornton in London on August 17 2004. Burrows, who began his career at Customs & Excise, will lead Grant Thornton's 40-strong indirect tax practice as the firm's new national head of VAT.
    August 31 2004
  • sulkowski-sep04.jpg
    Ernst & Young partners launch new firm in Luxembourg
    Alex Sulkowski: More and more constrained Five partners left Ernst & Young in Luxembourg on August 10 2004 to lead a team of 30 in setting up Atoz, a new international tax firm.
    August 31 2004
  • Canadian update: Supreme Court rules that interest expense is generally on account of capital
    The deductibility of interest expense is likely the tax issue on which the Supreme Court of Canada (the SCC) has commented most extensively
    August 29 2004
  • Vivendi strikes deal on French taxes
    Last Thursday Vivendi Universal, the entertainment and communications company, finalized a deal with the French government that would reduce its tax bill by several billion over a number of years in exchange for creating hundreds of new jobs in the country. The deal is the result of months of negotiations with the French finance ministry. It allows the company to use billions of losses it accumulated since the year 2000 to offset profit from non-wholly-owned subsidiaries, which it previously could not do.
    August 29 2004
  • Netherlands clarifies transfer pricing guidelines
    Joop Wijn, the Dutch state secretary of finance, on August 21 2004 issued a decree clarifying how the Netherlands will apply the arm’s-length principle and the OECD’s transfer pricing guidelines for multinational companies
    August 29 2004
  • US inbound update: Ruling restricts ability of foreign corporations to use US treaty benefits
    Revenue Ruling 2004-76 held that a foreign corporation (A), formed under the laws of country X, could not claim the benefits of the income tax treaty between the US and country X if under the income tax treaty between country X and country Y, it is treated as a resident of country Y
    August 29 2004
  • Mexican update: What the US social security covenant means
    The Mexican Institute for Social Security released on its website on June 29 2004 an agreement on social security contributions signed between the governments of Mexico and the US (the Social Security Covenant)
    August 29 2004
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