ITR Search | International Tax Review

Commissioner gets tough on tax evasion

The Commissioner of Inland Revenue (CIR) announced in the January 2003 issue of The Hong Kong Accountant, the official journal of the Hong Kong Society of Accountants (HKSA) that the Inland Revenue Department (IRD) would initiate prosecution action whenever it is warranted to combat tax evasion. This is a result of the tough approach taken by the court in delivering judgment against those who were wilfully intended to evade tax, and the court put them in prison.

March 01 2003

Taxation of share transfers held contrary to EC law

The ECJ has held that Swedish tax law relating to the taxation of certain share transfers is illegal under EC law.

March 01 2003

Recharacterizing the transfer of receivables

In terms of refinancing, the transfer of receivables can play a key role. In groups of companies, the transfer of receivables can also make it possible to transfer the burden of the financing of a subsidiary from one shareholder to another. The tax consequences of a receivable transfer may significantly differ from the expectations of companies.

March 01 2003

Foreign exchange reforms released

The first cut of the long-awaited reform to the foreign exchange (forex) rules has been released in draft by the Australian government. The draft legislation includes most of the measures announced in the 2002-2003 federal Budget concerning the taxation of foreign currency transactions, as well as changes designed to allow tax deferral on the conversion of traditional securities.

March 01 2003

New rules on non-resident salaries

Until 2003 salary income of non-residents was taxed in Spain when:

March 01 2003

Taxing companies by size

A new local enterprise taxation system will be introduced in Japan for tax years after April 1 2004, where a corporation will be taxed based on the size of its businesses measured by the value added, its capital, and its income. Under the new taxation system, a corporation with a tax loss will have to pay local enterprise tax. The new system is briefly summarized as follows.

March 01 2003

Foreign employees get public child support contributions

Thanks to a recent decision by Germany's highest tax court, foreign employees temporarily transferred to a German group subsidiary will generally be entitled to receive government child support contributions (Kindergeld) for their children living in Germany if their income is subject to German social insurance contributions (Federal Tax Court judgment of October 30 2002 - VIII R 67/99).

March 01 2003

Transfer pricing rules refined

In the course of 2002 few changes were made to the Brazilian transfer pricing legislation; the main one being the expansion of transactions subject to transfer pricing regulations. Following the enactment of Law 10451 (May 2002), transactions undertaken between unrelated Brazilian individuals or legal entities and foreign individuals or legal entities resident or domiciled in a country in which local legislation allows corporate ownership secrecy are subject to Brazilian transfer pricing regulations.

March 01 2003

Taking advantage of tax treaties in Latin America

The region's ever-expanding tax treaty network is providing new tax-strategy opportunities. Nicasio del Castillo, Jorge A Gross, Eduardo Pupo and John A Salerno of PricewaterhouseCoopers show where

March 01 2003

Japanese banks defeat Tokyo taxes

Japan's struggling banks have been granted a temporary reprieve after winning a High Court tax case against the Tokyo city government. The court ruled that taxes imposed by Tokyo city on banks were illegal and if this decision is upheld by the Supreme Court, the banks could see around ¥160 billion ($1.4 billion) returned to them.

March 01 2003

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