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  • How companies approach transfer pricing in the Asia-Pacific
    Ernst & Young's transfer pricing survey last year covered 638 parent companies and 176 subsidiaries in 22 countries, including Australia, Japan, Korea and New Zealand. The firm's David Lewis in Melbourne and Lisa Lim in Singapore uncover the trends emerging in the region
    August 31 2002
  • Getting the most out of Canada's protocol regime
    Canada's protocol regime aims to encourage a cooperative relationship between the CCRA and taxpayers and can yield significant benefits. By Hendrik Swaneveld, Martin Przysuski and Venkat Nagarajan, BDO Dunwoody, in Toronto
    August 31 2002
  • Corporate finance deals
    AWG
    August 31 2002
  • primarlo-sep02.jpg
    UK to overhaul corporate tax
    Dawn Primarolo, UK Paymaster General: businesses should read and respond to consultation Companies in the UK could look forward to a radical overhaul and simplification of the corporate tax system if government plans go ahead. The Treasury, together with the Inland Revenue, has announced that it is launching a consultation process to reform and modernize the tax system. The deadline for industry comment is October 29 2002.
    August 31 2002
  • Resolving transfer pricing disputes
    Tax disputes involving two or more treaty countries giving rise to an issue of double taxation are often resolved through discussions between the competent authorities under the mutual agreement procedure of most tax treaties. Canadian taxpayers that have been reassessed have the choice of disputing the reassessments in the domestic appeals branch of Canada Custom and Revenue Agency (CCRA) and/or submitting the case to the competent authorities.
    August 31 2002
  • ECJ rejects UK's retroactive three-year-cap on VAT repayment claims
    In a July 11 2002 decision (Marks & Spencer Plc v Customs & Excise Commissioners), the European Court of Justice (ECJ) held that the retroactive imposition of a three-year time limit on claims for refund of overpaid value added tax (VAT) was unlawful. The decision is particularly unusual in that it goes beyond the issue that had been referred to the court by the UK Court of Appeal.
    August 31 2002
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    New Supreme Court decision on realizing share losses
    In 1996 the Norwegian bank CBK (now Nordea Bank Norge) sold its shares in two subsidiaries to two other subsidiaries, seemingly realizing a huge taxable loss. Immediately afterwards the two subsidiaries that had been sold were merged - tax free - into the two respective subsidiaries that had bought them (see diagram 1 below).
    August 31 2002
  • Repatriating profits from Spanish holding companies
    The Brazilian tax authorities have for the past few months issued a number of regulations and rulings designed to preserve and/or modify the relevant tax basis. Some recent rulings and rules that are worthwhile to be mentioned are the following.
    August 31 2002
  • Valuation losses and net-operating-loss carryovers
    The Civil Rehabilitation Law (minji saisei-ho) went into effect on April 2000 and replaced the Composition Law (wagi). It outlines the basic restructuring procedures in Japan. By introducing a new legal framework, the main intention was to make it easier for small-and-medium-sized enterprises to take advantage of the provisions.
    August 31 2002
  • PwC dominates UK tax rankings
    PricewaterhouseCoopers is the leading tax firm in the UK according to a survey carried out by International Tax Review
    August 31 2002
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