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Luxembourg has threatened to undermine the European Commission’s savings tax directive unless the European Commission forces Switzerland to abandon its banking secrecy

A debt-to-equity swap (DES) is a term used for an exchange between a debt and an equity resulting from an agreement between the creditor and the debtor. It is performed when the debtor needs positive net equity or needs to improve its financial condition by reducing interest-bearing debts. The DES may take place as a result of a legal requirement, a private agreement between the debtor and creditor, or both.

The draft Tax Preferences Reduction Act (Steuervergünstigungsabbaugesetz or StVergAbG), which the German government announced in mid-October, released in early November, and then significantly modified just two weeks later, includes the most important changes in German transfer pricing law since the enactment of the Foreign Transactions Tax Act (Außensteuergesetz or AStG) in 1971. The new measures, passage of which is probable but not certain, represent a legislative response to the Federal Tax Court (Bundesfinanzhof) decision of October 17 2001, which held, among other things, that there is no basis in current German tax law for special transfer price documentation requirements (see articles by Alexander Vögele and William Bader in International Tax Review September 2001 p45 and February 2002 p22). The new rules would apply beginning with fiscal year 2003 (fiscal year 2003/2004 for non-calendar-year taxpayers) and hence take effect almost immediately.

The Russian State Duma (the lower chamber of the Russian Parliament) has recently passed and the Federation Council (the upper chamber) has approved a set of laws ratifying double tax treaties and protocols between Russia and a number of countries, in particular, Austria, Indonesia, Kuwait, Norway, Portugal and Sri Lanka, as well as a new protocol to the double tax treaty between Russia and Finland.

With close to 700 tax partners and 5,000 professionals throughout the Americas, KPMG leverages an extensive network of tax resources and knowledge to help multinationals turn tax challenges into competitive advantage?fast.

Despite their growing popularity, advance pricing agreements often fail to tackle the real issues that cause disputes between taxpayers and tax authorities. Alexander Vögele of KPMG and Markus Brem of Harvard Law School unravel the APA story so far

Alberto Terol has joined Deloitte Touche Tohmatsu in Madrid as deputy global managing partner, tax and legal. Terol was previously the area managing partner for western Europe at Andersen and had also been the managing partner of tax, legal and business advisory services at the firm.

Tom Offerhaus: foreign funds are right to complain The German government has incurred the wrath of foreign fund managers furious at proposed tax reform measures, which they believe discriminate against the fund industry in general in Germany and foreign funds.

By James Tobin, Ernst & Young’s global director of international tax services

The year's survey results of leading advisers show that the break-up of Andersen has significantly altered the tax landscape in Latin America. Sed Crest speaks to tax directors of multinationals operating in the region to uncover the reasons behind their votes