Search results for

Sixth VAT Directive – Article 9(2)(e) – Place of taxable transactions – Fiscal connection – Advertising services.

Sixth VAT Directive – Deduction of input tax – Possibility of opting for taxation of the letting of immoveable property – Abolition – Adjustment of deductions – Applicability to current leases – Protection of legitimate expectations.

As announced in our April 2003 international update, the Swiss federal tax authorities have issued on May 6 2003 an information letter (Rundschreiben) regarding taxation of stock options in Switzerland. This letter has a significant impact on the tax treatment of stock option plans in Switzerland. We believe that it is important to analyze the impact in detail for the issuing company and the individuals receiving stock options, as there are significant potential tax and social security saving opportunities.

The government announced several measures to relieve the financial pressure due to the adverse SARS effects. One way is to provide salary taxpayers with a tax rebate equal to half of the salaries tax paid for the year of assessment 2001/02 subject to a ceiling of HK$3,000 ($384). Taxpayers are not required to apply for the refunds. The Inland Revenue Department (IRD) will automatically work out their rebate amounts, and send the cheques to them by post. About 1.3 million refund cheques will be issued, and taxpayers will receive the refund from July 10-31 2003.

The Spanish framework for research and development (R&D) and innovation activities has traditionally been extremely advantageous, especially with regard to tax incentives, advantages which have been enhanced by a recent reform.

In a recent judgement (CIT v Vijay Ship Breaking Corporation and others [2003] 181 CTR 134), the Gujarat High Court has held that an Indian buyer is required to withhold tax from the usance interest paid to foreign suppliers.

On April 23 2003 the European Commission partly approved the proposed new rules for Belgian coordination centres (BCC). These new rules are designed to replace the old BCC regime, which the European Commission ordered on February 17 2003 to be phased out by the end of 2010.

Under Italian law, the sale of a going concern is outside the scope of value-added tax (VAT) - consistently with the EU VAT Directives - and is subject to registration tax, irrespective of the assets that are part thereof.

The 2003 Mexican tax reform restricted indirect foreign tax credits to only first-tier companies. This meant that any Mexican company that had an investment outside Mexico through a foreign-holding company would be unable to credit the foreign taxes paid by the second-tier company. Clearly, this had a significant negative effect on many Mexican multinationals or other transnational companies that used Mexico as a springboard for their Latin American investment.

International consulting firm LECG has hired a group of former Andersen staff to develop a European transfer pricing group in London. Former Andersen international tax partner Richard Fletcher is leading the group and has joined as a director. Senior economist Stephanie Pantelidaki and senior associate Darren Andrews joined the firm earlier this month. Both Pantelidaki and Andrews initially joined Deloitte & Touche when it merged with Andersen. Another ex-Andersen partner Nicholas Woolf is also working with the group as a consultant.