ITR Search | International Tax Review

Spanish update: Taxpayers gain from tweaks to the participation exemption

Effective January 1 2004, a new wording of the participation exemption has entered into force, correcting a troublesome requirement

March 07 2004

Mexico allows VAT rebate for foreign telecom companies

Foreign telecommunications companies could get relief from VAT on international telecommunications services provided by a Mexican entity to a non-Mexican entity. After changes to the Mexican federal fiscal code, companies can request a VAT refund from the Mexican tax authorities for certain transactions.

March 07 2004

English High Court turns down loss-relief hearing

Fifty five multinationals have failed to have their class-action style claim heard by the English High Court. The companies are claiming compensation similar to the claim in the Marks & Spencer case last year to offset losses made in other European countries against the profits of UK companies.

March 07 2004

Streekgewest Westelijk Noord-Brabant v Staatssecretaris van Financien; F J Pape v Minister van Landbouw, Natuurbeheer en Visserij

Interpretation of the last sentence of Article 93(3) EC (now Article 88(3) EC) – Prohibition of implementation of proposed measures – Designation of persons who may rely on an infringement – Scope of prohibition when aid consists in exemption from levy – Consequences of final decision for tax previously levied.

March 04 2004

Transport Service NV v Belgium

Article 104(3) of the Rules of Procedure – First and Sixth VAT Directives – Principle of fiscal neutrality – Application of VAT to each production or distribution transaction – Recovery.

March 03 2004

Ship hire charges payable to foreign ship owners not taxable

AMumbai tribunal has held in DCIT v. Reliance Industries Limited (81 TTJ 787) that the charges paid to a foreign company outside India for the hire of ships are not taxable in India.

March 01 2004

Ireland moves ahead as a holding company location

Several EU member states have established attractive holding company regimes. Pat Cullen and Evelyn Forde of Deloitte consider a number of new measures in Ireland's new Finance Bill which will improve its atractiveness in this regard

March 01 2004

IRS proposes new rules for intra-group activities

Taxpayers must pay attention to proposals in new transfer pricing regulations, which give the IRS substantial discretion to override the method selected by a taxpayer, argue Ken Wood and David Canale of Ernst & Young

March 01 2004

Bush Budget to reform international tax

The Bush Administration's 2005 Budget proposal and the Treasury's so-called Blue Book (General Explanations of the Administration's Fiscal Year 2005 Revenue Proposals), both published in early February, seek to reform US international tax law in a number of ways.

March 01 2004

UK Crown dependencies cut corporate tax rates

Governments in the Isle of Man and the Channel Islands are moving towards 0% rates of corporate tax in response to EU and OECD pressure on harmful tax practices and to compete with each other for essential foreign direct investment.

March 01 2004

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