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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

Corporate tax rate to be cut in Latvia

The government of Latvia plans to cut corporate income tax (now 19%) by four percentage points. The government detailed the plans in a draft budget bill for 2004 and presented them to the Latvian parliament on September 30 2003.

November 01 2003

Budget overhauls thin-capitalization and CFC rules

The first draft of the new 2004 State Budget Bill that has been made public contains a couple of relevant changes to the rules on thin capitalization and controlled foreign corporations (CFCs). The changes are the direct consequence of recent European Court of Justice case Lankhorst-Hohorst (thin capitalization) and European Commission actions (CFCs).

November 01 2003

Russia outlines corporate tax strategy

The Russian Taxes and Levies Ministry has detailed plans to improve corporate income tax collections. The ministry has prepared modifications to chapter 25 (corporate income tax) of the Russian Tax Code, which include changes to securities transactions, financial instruments and trust and other fixed-term transactions.

November 01 2003

Baker & McKenzie adds corporate tax director

Philippe Lion, a corporate tax director at PricewaterhouseCoopers in Brussels, will join Baker & McKenzie. Lion will focus on corporate and international tax at the firm from November 1 2003.

November 01 2003

Skadden sets up tax practice in Germany

The US law firm Skadden, Arps, Slate, Meagher & Flom has hired Hans-Georg Berg from Haarmann, Hemmelrath & Partner to head up its new tax practice in Frankfurt.

November 01 2003

Supreme Court allows Treaty benefits to Mauritian residents

In a landmark judgment (Union of India v Azadi Bachao Andolan), the Supreme Court of India has upheld the validity of Circular 789 dated April 13 2000 issued by the Central Board of Direct Taxes (CBDT) clarifying that a Certificate of Residence issued by the Mauritian authorities would constitute sufficient evidence for accepting the status of residence as well as beneficial ownership for claiming benefits under Indo-Mauritian Double Taxation Avoidance Agreement (DTAA).

November 01 2003

Appointment of director highlights APA developments

Much attention has been focused on the issuance of new regulations such as the final regulations regarding stock-based compensation and proposed new regulations governing services. But there has been no lack of development in the IRS's advance-pricing agreement (APA) programme.

November 01 2003

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