Search results for

The French Finance Law of 2002 significantly amended section 209II of the French Tax Code (FTC) relating to the transfer of NOLs (net operating losses) in corporate restructuring (mergers, spin-offs, split-offs and contributions of business lines). French tax authorities issued administrative guidelines on this new provision (August 21 2002, 13 D-2-02) in which they notably made comments upon cross-border transactions.

Many banks and companies are now engaged in debt restructuring negotiations but are unaware of the minefield through which they walk. Heléna Klumpp of Chadbourne & Parke LLP, Washington looks at the tax issues involved and suggests ways to plot a course

The IRS has issued its final QI audit guidelines. Now the first QI audit is approaching. It will be a landmark for financial institutions and auditors and will test the practicality and efficiency of the QI withholding system. Chip K Collins, KPMG, Washington DC, and Hans-Dieter Wolf, KPMG, Düsseldorf report

Pamela Olson has been sworn-in as US treasury assistant for tax policy. Treasury secretary Paul O'Neill swore-in Olson on September 26 this year. Olson has supervisory responsibility for providing the treasury secretary with policy analysis, advice and recommendations relating to all aspects of domestic and international issues of federal taxation including legislative proposals, regulatory guidance and tax treaties. She will also deal with official estimates of government receipts for the president's budget, fiscal policy decisions and treasury cash management decisions.

Marc de Bruijn: wanted the challenge of leading a group SchutGrosheide, the Dutch law firm and member of UK firm DLA's European alliance, D&P, has boosted its tax department with the appointment of three tax specialists.

The European Court of Justice (ECJ) Advocates General (AG) recently concluded in two separate cases that certain Dutch corporate income tax rules and the German thin capitalization rules conflict with the freedom of establishment principle in article 43 of the EC treaty.

During the last week of September, two prosecution cases on tax evasion were heard in the courts. It is rare that the Hong Kong Inland Revenue Department (IRD) brings two cases almost simultaneously to the court for prosecution.

The amended Detailed Rules on the Implementation of the PRC Law on Tax Collection and Administration provides stricter policies for transfer pricing activities in the PRC. Under the new rules, taxpayers are obliged to provide details on the value and fees of transactions between related companies.

Italy's proposed new tax reform sets out to learn from other EU country's experience and be innovative, competitive and simple to apply. Stefano Serbini and Lorenza Fiori of Ashurst Morris Crisp, Milan examine the proposals and explore the implications for Italian companies and foreign investors

National vetoes on taxes mean that European direct tax initiatives have so far fallen flat. But the advocate general and the European Court of Justice (ECJ) are making up for this lack of activity and in the last month alone have given several opinions that could create big benefits for companies. The judgments in late September and early October affect interest deductions across the EU and the possibility of cross-border pension contributions.