ITR Search | International Tax Review

What the Amoco decision means for captive insurance

On October 2002 the Norwegian Supreme Court made a decision regarding Amoco Norway and its right to deduct insurance premium paid to an intra-group insurance company, Northern Resources Assurance (Northern).

February 01 2003

US Protocol amends dividends and income rules

An additional Protocol to the existing US-Mexico Income Tax Treaty was signed recently in an effort to bring the treaty relationship with Mexico into closer conformity with US treaty policy and certain domestic legislation, as well as to take into account the recent changes in the laws and policies of both Mexico and the US.

February 01 2003

Tax reform plans revealed

The Ministry of Finance announced the tax reform plan for 2003 on December 19 2002. The proposed changes include the following items.

February 01 2003

Mini tax reform changes on PIS and tax avoidance

The Brazilian government issued Provisional Measure 66/2002 (PM 66/2002) on August 29 2002. Among several other changes, PM 66/2002 had altered the rules for the application of the social integration program tax (PIS), and introduced new provisions with respect to tax avoidance.

February 01 2003

When minority shareholders attack transfer prices

Transfer pricing professionals face a new challenge. Francois Vincent, Steven D Harris and Paul Burns of KPMG report on the case that is changing the landscape in North America

February 01 2003

Marks & Spencer loses group losses appeal

Retailer Marks & Spencer may have lost its tax appeal against the UK Inland Revenue, but it is not all bad news for companies looking for equal treatment throughout the EU.

February 01 2003

Special focus - Belgium: Understand the new DRD and withholding tax regime

As part of its tax reforms, Belgium has reworked its participation exemption and withholding tax regime. Kurt De Haen of PricewaterhouseCoopers analyzes the implications

February 01 2003

Big four spared in SEC guidelines

Alenient Securities and Exchange Commission (SEC) has granted the big four permission to provide tax services to audit clients into the foreseeable future. Results of the US organization's January 22 open meeting on auditor independence indicate that accounting firms will not have to restructure operations and can continue providing tax services to audit clients with few limitations. The results shift the burden of deciding what is and what is not a permissible service to the company's audit committee.

February 01 2003

Big four turn to China

With China gradually opening up its market and joining the World Trade Organization, demand for tax advice is booming in the mainland. In the last month alone Ernst & Young (EY) has boosted its China tax practice with five partners and intends to triple its tax group in the next three years. The big four firm has relocated four partners from its Hong Kong office including Stephen Lau Sing-hung, the firm's chair of tax services in China and Alfred Shum with Shum going to Shanghai and Lau moving to Beijing.

February 01 2003

Group relief for European losses rejected

The Special Commissioners have recently denied Marks & Spencer the right to obtain group relief in respect of losses incurred by certain European subsidiary companies in Belgium, France and Germany and have declined to make a reference to the European Court of Justice (ECJ) (Marks & Spencer plc v David Halsey (HM Inspector of Taxes) (Special Commissioners 352) December 17 2002).

February 01 2003

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