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  • by Timothy J McCormally, Executive Director, Tax Executives Institute
  • The Lovells tax practice comprises 18 tax partners and 35 associates. Lovells provides a comprehensive range of international and domestic business and corporate tax planning services. The firm has its own tax capacity in the offices listed below.
  • Companies will soon need to adjust to new rules governing the utilization and creation of revenue losses, if legislation currently before parliament is enacted. The changes are largely beneficial to companies and are proposed to apply from the income year in which July 1 2002 falls.
  • Attorneys ? Tax Advisors
  • José Abascal, 45, 28003 Madrid, Spain
  • Zurich, Switzerland
  • Dave Rutges, Eduard Sporken and Miodrag Verwoert of KPMG Meijburg & Co investigate how advance pricing agreement practice has changed in the Netherlands
  • 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.
  • According to the reform enacted through Law number 25,585 (published in the Official Bulletin on May 15 2002) foreign investors are subject to the personal assets tax on their participation in local companies. Decree 988 (published in the Official Bulletin on April 29 2003) clarified many aspects of the new tax.
  • The use of domestic reverse hybrids in cross-border financing continues despite the issuance by the Internal Revenue Service (IRS) of regulations designed to shut down abuses in the area. These devices, if structured correctly, may enable taxpayers to enjoy double-dip tax benefits with respect to interest expense and reduced withholding under US income tax treaties.