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  • 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
  • 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
  • Irish update: Imminent changes to capital acquisitions tax
    Capital Acquisitions Tax (CAT) is a tax imposed on gifts and inheritances (benefits), which exceed certain tax free thresholds
    August 29 2004
  • UK tax authority softens disclosure rules
    The Inland Revenue last week provided an assurance to tax advisers worried about the scope of the UK’s new tax disclosure regulations, which are designed to crackdown on the promoters of potentially abusive tax schemes
    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
  • 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
  • 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
  • Spanish update: New tax framework comes into force
    A new Ley General Tributaria (General Taxation Law) was published on December 17 2003 (Law 58/2003)
    August 29 2004
  • What tax directors want in Asia
    The cover story of the September issue of International Tax Review analyzes the responses from more than 380 tax directors, chief financial officers and other in-house tax executives doing business in Asia
    August 29 2004
  • Brazil reduces taxes on financial investments
    Investors in Brazil will get a better return on their money after the government reduced capital gains tax (CGT) on long-term financial investments and abolished social contribution taxes (PIS and COFINS) on financial revenues
    August 21 2004
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