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  • The tax shelter opinion standards that the US Treasury and the IRS first proposed at the end of 2003 in proposed changes to Circular 230 will be finalized soon, according to a Treasury official. There have been concerns that ordinary tax planning would trigger the rules. But Eric Solomon, Treasury deputy assistant secretary (regulatory affairs) said the comments on the proposals submitted by tax advisers would be incorporated in the new regulations.
  • US law firm Pillsbury Winthrop announced on April 2 2004 that Timothy Burns, who joined the firm in 1989 and became a partner in 1997, has rejoined the tax practice after a year with Lombard Investments. Burns' practice focuses on tax, partnership and private equity matters.
  • A survey by KPMG has found that global corporate tax rates continued to fall in most parts of the world. The 2004 survey found that the average rate for the members of the thirty OECD nations (Organisation for Economic Cooperation and Development) fell from 30.68% in 2003 to 29.96% in 2004.
  • The Norwegian government unveiled tax reform proposals on March 26 2004. The reforms would make inter-company dividends and inter-company capital gains on shares tax-free, and corresponding losses would be non-deductible. To prevent a tax-motivated realization of losses, that part of the reform would come into force from the day the proposal was presented. The rest of the reform would be phased in over the years 2005 to 2007.
  • The European Commission (EC) rejected Gibraltar's proposals for company tax reform on March 30 2004. The proposals would have replaced Gibraltar's 35% corporate tax rate with a payroll tax and a business property occupation tax that together could not exceed 15 % of company profits. But the EC ruled that the proposals would contravene EU state aid rules. The Gibraltarian government has pledged to challenge the decision.
  • The German tax authorities released guidelines on March 29 2004 clearing up long-standing confusion over the classification of limited liability companies (LLCs) for tax purposes as either a partnership or a corporation
  • The New Zealand government is taking action against companies that might be tempted to avoid tax by entering sale and leaseback deals on their intellectual property
  • Both Japan and the EU have supported the US complaint to the World Trade Organization over China's value added tax (VAT) policy to domestic semiconductor manufacturers. The complaint, made on March 18 2004, centres on an effective VAT rate of just 3% for Chinese semiconductor manufacturers compared to a 17% rate for all foreign equivalents.
  • KPMG piloted the UK’s first fully electronic system for companies to approve and file their corporation tax returns over the internet in late March 2004
  • In a decision dated November 3 2003 (Conseil d'Etat, 244437, SARL Meridia France), the French Administrative Supreme Court had to decide whether the interest paid by a French company to a partner domiciled abroad as current account remuneration may benefit from the withholding tax exemption provided by section 131(4) of the French tax code