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  • New Zealand tutors companies on tax returns
    The Inland Revenue Department in New Zealand has issued a 10-point checklist for companies to consider when completing their tax returns. The list includes the adequacy of transfer pricing documentation, company involvement in complex transactions and structures, the presence of excess credits or capital gains and participation in transactions with tax haven jurisdictions.
    November 01 2003
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    What the Bosal case means for Europe
    Allen & Overy's Olaf van der Donk and Olaf Kroon explain why acquisition and finance structures will change dramatically
    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
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    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
  • 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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    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
  • Multinationals fail to retrieve advance corporation tax payments
    More than 70 multinationals failed to reclaim hundreds of millions of pounds from the UK Inland Revenue in a high court group litigation case on advanced corporation tax (ACT)
    November 01 2003
  • A flurry of double taxation agreements
    Ireland now has double taxation agreements (DTAs) with 41 countries. A complete list of these DTAs can be seen at www.mop.ie.
    November 01 2003
  • EU threatens sanctions over US exports tax breaks for exporters
    The US is on course to miss the EU's year-end deadline to remove the $4 billion tax break for exporters that the WTO deemed illegal more than two years ago. If the US misses this deadline, the EU could carry out its threat to launch trade sanctions.
    October 30 2003
  • Japan plans tax surcharge for consolidated companies
    Japanese government looks set to introduce a 2% tax surcharge on companies paying taxes on a consolidated basis. The new tax is expected to take effect in April 2004 for a period of two years and would partly compensate for an expected drop in corporate tax revenues if companies are allowed to pay taxes on a consolidated basis.
    October 30 2003
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