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  • Tribunal rules on professional services fees
    The Mumbai Tribunal in Maharashtra State Electricity Board v. DCIT (83 TTJ 325), examined applicability of the old India-UK Double Tax Avoidance Treaty (DTAA), which was substituted by new DTAA in 1994, to fees received by a UK-based firm of solicitors for legal services provided to an Indian company.
    May 31 2004
  • Legislation proposes extending limitation periods for federal tax debt collection
    The Canadian Supreme Court decision last year in Markevich v. The Queen affirmed that federal limitation periods may limit collection of long-outstanding tax debts. However, many advisers speculated that the taxpayer's victory would be temporary at best given the Crown's public requests that the law be changed.
    May 31 2004
  • Collection of social contributions on imports
    The Brazilian government issued on January 29 2004, Provisional Measure (PM) 164/2004. This PM introduced new regulations to subject imports of goods and services to the social integration program contribution-import (PIS) and social security financing-import (COFINS).
    May 31 2004
  • Change of government clouds business tax climate
    Iraq does have corporate tax rules in spite of the year-long turmoil. But they could be changed after the transfer of sovereignty in June 2004, warn Mahyra Roy and Michel Picard of KPMG
    May 31 2004
  • Taxes rise for bringing talent into Brazil
    The Brazilian economy could be the loser from the increase in the tax burden on the import of services, warn Gustavo Haddad and Bruno Carramaschi of Goulart Penteado, Iervolino e Lefosse Advogados, in cooperation with Linklaters
    May 31 2004
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    IntraPrice
    IntraPrice is an independent firm specialized in offering transfer pricing services. It is well recognized for its practical approach and hands-on support tailored to the needs of each client. The company is staffed by specialists with extensive transfer pricing, international tax, economic and business experience. www.intraprice.com
    May 31 2004
  • Exit tax planning window opens
    In March 2004 the European Court of Justice (ECJ) invalidated a French statute that taxed the unrealized appreciation inherent in corporate stock held by long-term French resident individuals upon transfer of their tax residence from France to another country (Hughes de Lasteyrie du Saillant - Case C-9/02).
    May 31 2004
  • Case questions Finnish credit system
    Advocate General Kokott issued her non-binding opinion in the Manninen case (C-319/02) on March 18 2004 regarding the compatibility of the Finnish tax credit system with the EC Treaty. In Finland, economic double taxation of corporate profits is avoided by crediting corporate income tax paid by the company against the income tax payable by the individual on the dividend received. The credit is denied, however, if the company distributing the dividend is not a resident of Finland.
    May 31 2004
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    How the UK and Germany have treated ECJ rulings on article 43
    EU member states should consider a common policy on tax rates and reliefs. It may help them deal with treaty issues raised by the European Court of Justice, argue Timothy Jarvis, Jens-Uwe Hinder and Dirk Koehler of Hammonds
    May 31 2004
  • apas-diag1-jun04.gif
    APAs are set to take off in Europe
    The first three multilateral advance pricing agreements have been concluded in Europe. Similar agreements are likely to grow in popularity, according to Dave Rutges, Eduard Sporken, Dirk Van Stappen and Pascal Luquet of KPMG
    May 31 2004
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