ITR Search | International Tax Review

IRS marches on in war on tax shelters

Senate Finance Committee hearings in Washington DC, reveal that while the US Internal Revenue Service (IRS) is unrelenting in its initiative to crack down on so-called abusive tax shelters, it still has its work cut out.

November 01 2003

France separates tax and audit services

The big four accounting firms could be barred from offering non-audit services to audit clients under a law regulating the financial services industry (Loi de Securité Financière) announced in August 2003. The French government expects to introduce regulations that will provide more detail, possibly early next year.

November 01 2003

New tax Treaty with Australia

On September 2003 the Mexican Congress approved the Mexico - Australia Tax Treaty (the Tax Treaty).

November 01 2003

UK R&D credits fail to attract

Tax breaks for research and development (R&D) in the UK could save domestic and multinational companies millions of dollars each year but many companies are not making R&D tax relief claims because of unclear guidelines and cumbersome procedures.

November 01 2003

How to outsource financial services tax-effectively

Nick Cronkshaw and Martin Shah of Simmons & Simmons focus on the practical tax aspects when outsourcing in the banking, asset management and insurance sectors

November 01 2003

US IRS releases treaty list for reduced dividend tax rates

The IRS issued a list of the US tax treaties that meet the requirements for reduced capital gains rates on certain dividend payments under the Jobs and Growth Tax Relief Reconciliation Act 2003 on September 30 2003. The notice lists 52 treaties and is effective for taxable years beginning after December 31 2003.

November 01 2003

Visa liable to tax in India

The competent authorities of India and the US agreed that the credit card organization Visa International is subject to tax in India because the company's server constitutes a permanent establishment in the country. Visa International had resisted attempts by the Indian revenue authorities to tax the company for the portion of its profits attributable to Indian operations.

November 01 2003

Tax reform package targets international transactions

In order to fulfil the government's aim to introduce a series of measures to mitigate tax evasion, the Argentine executive has finally promulgated, on October 21 2003, a tax reform Bill where for exports of grain, hydrocarbons and other commodities involving a foreign intermediary, the fair-market price of the goods at the date of loading may be used rather than the price fixed in the transaction if the intermediary does not fulfil certain conditions.

November 01 2003

What Bosal means in Germany

The European Court of Justice (ECJ) rendered its decision in the matter of Bosal Holding BV on September 18 2003 (C-168/01). The central issue in Bosal was whether an EU member state may deny a deduction for costs incurred by a domestic parent company with regard to a foreign EU subsidiary (to finance the shareholding for example) where neither the foreign subsidiary's profits nor the dividends it pays are subject to tax in the parent company's home jurisdiction.

November 01 2003

Why Swedish holding companies are attractive

Mats Anderson and Lars Jonsson, of Linklaters, explain why Sweden's new rules on tax-exempt capital gains and dividends and holding structures make it an attractive location

November 01 2003

Search results for