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  • Poland calls for EU corporate tax harmonization
    The government of Poland joined France and Germany on July 12 2004 in calling for the harmonization of EU member states' corporate tax regimes. Andrzej Raczko, the Polish finance minister met with his French and German counterparts in Warsaw to discuss the harmonization issue and described the Franco-German initiative as essential for conducting business effectively throughout the EU.
    June 30 2004
  • ConocoPhillips faces tax fraud claims
    The US energy company ConocoPhillips is facing a law suit in a US district court from Oceanic Exploration Co and its subsidiary, Petrotimor Companhia de Petroleos over claims that ConocoPhillips committed tax fraud and other crimes in gaining its Timor Sea oil fields in south-east Asia. Oceanic is seeking $10.5 billion in damages.
    June 30 2004
  • Minister reveals Budget shock for banks and corporations
    Though the Minister of Finance's Budget presented in February was described as bland, there was a shock which will affect banks and corporates. That is the announcement of the intention to re-categorize certain financing instruments in accordance with their "economic substance". As has been done in other countries, rules will be written into the Income Tax Act to re-categorize these instruments for tax purposes. Typical examples that might include re-categorizing:
    June 30 2004
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    US updates procedures on advance pricing agreements
    The US Internal Revenue Service (IRS) issued updated procedures on July 1 2004 that taxpayers can use to request advance pricing agreements (APAs). The procedures were designed to simplify the process of arranging APAs and to encourage bilateral and multilateral APAs to avoid double taxation.
    June 30 2004
  • Supreme Court rules on India-Malaysia tax treaty
    The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty.
    June 30 2004
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    Treaty highlights issue of participation exemption
    A Brussels court has just ruled that a dividend of Hong Kong origin is entitled to Belgium's 95% participation exemption, according to Kurt De Haen and Magalie Delattre of PricewaterhouseCoopers
    June 30 2004
  • Transfer pricing reforms follow international practice
    Colombia's new transfer pricing rules set out clearly what is expected of taxpayers, according to Ricardo Rosero, Bernardo Solano, and Fabián Alfonso of BaseFirma
    June 30 2004
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    Structuring multinational groups in Europe
    The number of EU member states increased from 15 to 25 on May 1 this year. In a single move, the opportunities to structure investments for multinational groups in Europe multiplied, according to Götz Wiese and Henrik Lay of Latham & Watkins
    June 30 2004
  • High court backs retailer in UK VAT case
    A test case brought by Debenhams, a UK retailer, could cost Customs & Excise as much as £300 million ($549 million) in lost revenue. The June 29 2004 High Court ruling upheld Debenhams' appeal against an earlier tax tribunal decision that said the company was guilty of avoiding value-added tax (VAT).
    June 30 2004
  • Tax efficiency features in new SICAR structure
    New legislation aims to encourage private equity and venture capital investment via Luxembourg. Dean Rolfe of PricewaterhouseCoopers discusses the role tax plays in the new vehicle
    June 30 2004
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