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  • UK update: Real estate investment trusts planned
    In the pre-Budget speech in December 2003, UK real estate investment trusts (REITs) moved one step closer with an endorsement from the Chancellor, Gordon Brown, who confirmed that a consultation document on REITs would be issued with the Budget in March this year
    March 14 2004
  • Italian update: New group company rules bring up permanent establishment issues
    Legislative Decree 6 of January 17 2003, reforming Italian company law, with effect from January 1 2004, introduced in the Italian Civil Code (the ICC) specific rules related to groups
    March 14 2004
  • German update: Value-added tax invoicing changes
    Germany enacted many changes in its value-added tax (VAT) law in December 2003
    March 14 2004
  • EU ministers reject Swiss stalling on savings tax
    European Union finance ministers in Brussels increased pressure on Switzerland to sign an accord on offshore tax fraud at the monthly Ecofin council meeting on March 9 2004
    March 14 2004
  • IRS responds to advance pricing agreement inquiry
    On March 11 2004 the Internal Revenue Service (IRS) in the US delivered its reaction to the Senate Finance Committee's inquiry into advance pricing agreements. The committee asked the IRS on December 22 2003 to produce findings on whether multinationals were unfairly avoiding tax through such agreements as well as copies of all agreements over the past 10 years and the recommended transfer pricing methods.
    March 14 2004
  • Austria to cut corporate tax to 25%
    The Ministry of Finance has released a draft tax reform package that will reduce the tax burden by €3 billion ($3.7 billion). The package, if passed, which will likely take effect from January 1 2005, cuts corporate income tax from 34% to 25%, revamps treatment of group losses, makes interest incurred for the participation acquisitions deductible but removes capital gains neutrality for new assets in some cases.
    March 14 2004
  • Germany to repay capital gains tax levied in 1997 and 1998
    On March 9 2004 the Federal Constitutional Court declared that capital gains taxes levied in 1997 and 1998 were unconstitutional due to bank secrecy laws. The capital gains legislation has since been amended but taxpayers can seek repayment of such taxes paid in 1997 and 1998.
    March 14 2004
  • Netherlands signs tax protocol with the US
    On March 8 2004 the US and the Netherlands signed a protocol to the 1992 tax treaty that, in some circumstances, eliminates withholding taxes on dividends paid to parents within the two countries. The protocol also updates the limitation of benefits arrangements and includes new rules on partnership investments.
    March 14 2004
  • US Senate ratifies Japan treaty
    The US Senate ratified the tax treaty with Japan on March 9 2004. The Japanese Diet needs to ratify the agreement by April 1 2004, to allow provisions on reduced withholding tax on dividends, interest and royalties to take effect from July 1 2004 rather than next year.
    March 14 2004
  • ATO claims Toyota owes up to $700 million in unpaid tax
    Toyota Australia is facing a claim by the Australian Taxation Office (ATO) that it shifted profits offshore, avoiding about $300 million to $700 million in taxes between 1994 and 1999. Toyota's spokesperson, quoted by the Australian Broadcasting Corporation, has rejected the claim and says it is working with the ATO to finalize the review.
    March 14 2004
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