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  • Law 9430 introduced the transfer pricing regime in Brazil on December 27 1996. Under this law, Brazilian taxpayers were allowed to use three different methods to control their import transactions with related parties resident and domiciled abroad:
  • The UK employment-securities rules changed substantially in the Finance Act 2003. The haphazard way they were introduced didn’t help taxpayers to try to understand them, believes Darren Oswick of Simmons & Simmons
  • Alf Capito and Leonid Shaflender of Ernst & Young discuss the recent international tax reforms introduced to increase the attractiveness of using Australia for business and investment
  • Reserve Bank figures for 2003 The Reserve Bank's figure for 2003 National Bank's pre-tax profit was NZ$439 million ($293 million) with reported tax NZ$143 million ($95 million), whereas the tax paid was NZ$70 million ($47 million).
  • The Venezuelan government has published amendments to its value-added tax (VAT) law. The amendments reduce the regular VAT rate from 16% to 15% and allow taxpayers to set off excess VAT withholdings against any national taxes due. The amended law will enter into effect on September 1 2004.
  • Dutch telecommunications firm KPN is preparing to file a lawsuit against the Netherlands government for a ?120 million ($146 million) value-added tax (VAT) refund for third-generation mobile phone licenses.
  • A Latvian with a reputation for euroscepticism will become the commissioner for taxation and customs union when the new EU Commission takes office on November 1 2004.
  • Example 1 One of the miscellaneous amendments to the loan relationship regime in the Finance Act 2004 (FA) was to amend the rules relating to the taxability of releases of debts where the parties are connected but where one (or both) is in some form of insolvency proceedings. This can often occur when a subsidiary is sold and before the sale the debt owed by that subsidiary is written off to tidy up its balance sheet.
  • 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).
  • 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.