Search results for

Baker & McKenzie's Global Tax Practice has had an international focus since the Firm was established in 1949. More than 50 years of development has produced an unparalleled level of experience and professional resources internationally. With more than 450 tax attorneys in 36 countries Baker & McKenzie has the infrastructure and depth of talent to provide global integrated tax and legal solutions.

Nearly 18 months on and the Enron fallout shows no sign of dissipating. First the US set about creating legislation governing the accounting profession, and in the run up to last summer's Sarbanes-Oxley Act, concerns about the type of services that accounting firms would be able to provide grew. The final legislation came as a relief to the big four, as they were allowed to keep both tax and audit services within the same firm, but now attention is turning to France.

PricewaterhouseCoopers' tax and legal specialists help clients gain business advantage by providing multi-disciplinary and innovative solutions to their complex business issues.

The Tax Department is currently made up by six partners and five senior associates, assisted by around 20 other tax lawyers from the offices of Madrid, Barcelona, Valencia, New York, Lisbon and Sao Paulo. The Department advises on all Spanish, Portuguese and Brazilian direct and indirect taxes, but has particular expertise in mergers and acquisitions, financial products and capital markets, international tax planning, real estate transactions and project finance, assurance and pension funds and tax investigation and disputes.

Todd M Landau of PricewaterhouseCoopers investigates permanent establishment challenges to related party cost-plus service arrangements

The Brazilian Central Bank issued on April 16 2003 Circular 3187 modifying articles 9 and 10 of Circular 2677/96. The latter relates to non-resident accounts maintained in reais (local currency) with a Brazilian financial institution (commonly referred to as CC5 accounts) and international transfer of reais. The CC5 accounts allow individuals and companies to undertake international transfer of reais to bring funds to Brazil or send them abroad. Such accounts are ordinarily used for payments of dividends, capital increase/reduction, inter-company loan arrangements and Brazilian investment abroad.

In a radical change, UK stamp duty is to be replaced by stamp duty land tax (SDLT). UK stamp duty is a tax on documents as to their effect(s) that relate to anything done or to be done in the UK. Stamp duty is voluntary in the sense that the Crown cannot generally sue for its recovery. It is often paid because an unstamped document cannot be used for any purpose whatever (such as proving and registering title).

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.

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.

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.