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Brazil update: Export transactions can exclude social contributions

Two Brazilian courts of first instance have issued important decisions relating to the application of the Brazilian social contribution on net income (CSLL) for income derived from export transactions

November 23 2003

Ireland Update: A flurry of double taxation agreements

Ireland now has double taxation agreements (DTAs) with 41 countries

November 23 2003

Russia toughens stance on tax evasion

The Russian government has closed a loophole in the country’s Criminal Code which allowed taxpayers with outstanding liabilities to avoid punishment if they agreed to pay tax arrears and fines voluntarily

November 23 2003

Japanese government proposes extended tax breaks

Japan's Tax Commission, an influential government advisory body, proposed to extend the period that companies can carry over their losses from five to seven years. Companies in Japan can carry forward losses for up to five years and offset part of any profit incurred in the following fiscal years with the losses, reducing the size of their taxable income.

November 23 2003

Kuwait scraps corporate income tax for foreign businesses

The government of Kuwait announced a 10-year corporate income tax exemption for foreign business on November 16 2003. The tax exemption will begin from the date that businesses begin their commercial operations in the country and is designed to encourage foreign investment.

November 23 2003

Assurandør-Societetet, acting on behalf of Taksatorringen v Skatteministeriet

Sixth VAT Directive – Article 13A(1)(f) and 13B(a) – Exemption for services performed by independent groups not likely to give rise to distortions of competition – Exemption for insurance transactions and related services performed by insurance brokers and insurance agents – Assessments of damage caused to motor vehicles carried out by an association on behalf of insurance companies which are members of that association

November 20 2003

Margarete Unterpertinger v Pensionsversicherungsanstalt der Arbeiter

Sixth VAT Directive – Exemption for medical care provided in the exercise of the medical and paramedical professions – Expert medical report.

November 20 2003

Peter d'Ambrumenil, Dispute Resolution Services Ltd and Commissioners of Customs and Excise

Sixth VAT Directive – Exemption for medical care provided in the exercise of the medical and paramedical professions.

November 20 2003

Kirkland & Ellis lures PricewaterhouseCoopers senior partner

Senior PricewaterhouseCoopers tax partner Ian Taplin will join Kirkland & Ellis early next year. The move will see Taplin re-qualify as a solicitor and join the US firm as a partner and head of international tax at its city arm in London.

November 16 2003

Argentine update: 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 16 2003

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