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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

Budget committed to 12.5% corporate tax

Despite a very tight budgetary backdrop, Ireland's Minister for Finance has used the occasion of his annual Budget to confirm the introduction of the much-heralded 12.5% corporate tax rate on trading profits with effect from January 1 2003.

February 01 2003

France promises tax cuts

French president Jacques Chirac has reportedly promised to continue cutting income tax and social security charges even though growth is lower than predicted. According to the Reuters news service Chirac promised the cuts in his New Year's address to the French National Assembly and Senate.

February 01 2003

KPMG hires IRS official

KPMG has hired Sean Foley, former director of the US Internal Revenue Service's (IRS) advanced pricing agreement (APA) programme. Foley will split his time between New York and Washington.

February 01 2003

New Year brings tax overhaul

Significant tax reform has come into force in Spain effective January 1 2003. It affects personal income tax and some aspects of non-resident income tax and corporate income tax. In the October 2002 issue of International Tax Review, this column anticipated some aspects of the reform, which was then underway. All such changes have remained unaltered in the final wording of the law. Other changes worth mentioning are as follows.

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

What the US mid-term elections mean for earnings stripping

Multinationals doing business in the US should be worried about how the Thomas Bill will affect their business. PricewaterhouseCoopers' Oscar Teunissen and Larry Skor in New York and Christine Halphen, Steve Nauheim and Linden Smith in Washington DC explain why

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

Osler gains from EY's Donahue demise

Al Meghji: Wanted to focus on law Canadian firm Osler Hoskin & Harcourt has benefited from the collapse of Ernst & Young's Canadian law firm Donahue. The firm has picked up one partner and three associates for its tax litigation group. Al Meghji has joined the firm from Donahue and splits his time between the Toronto and Calgary offices. Two associates have moved with him to Calgary and the third is joining the Toronto office.

February 01 2003

Chief Executive seeks to boost revenue

On January 8 2003 the Chief Executive of the Hong Kong Special Administrative Region, Tung Chee Hwa, delivered his policy address. He foresaw that the Hong Kong government US deficit for the fiscal year 2002-03 might exceed HK$70 billion ($9 billion). The government will adopt a three-pronged approach to eliminate the deficit and arrive at a balanced budget in 2006-07. They are boosting economic growth, cutting public expenditure and raising revenue.

February 01 2003

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