Search results for

Potentially sweeping reforms, political tensions and aggressive revenue authorities all feature on the Nordic tax scene. However, as International Tax Review discovers, there are also plenty of benefits for business

The introduction of the consolidated tax return system is the most significant change to come out of the 2002 tax reform. Other changes are described below. The tax base has been expanded on account of the anticipated reduction in tax revenues caused by the implementation of the consolidated tax return system.

Under certain conditions, article 5(1) of EU Council Directive 90/435/EEC of July 23 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different member states, provides for the elimination of withholding taxes on dividends paid between companies settled in the EU. In a decision rendered on October 4 2001 (Case C-294/99 Athinaki Zytopoiia AE), the European Court of Justice (ECJ) ruled that the tax to which certain Greek companies are subject on some profit distributions was a withholding tax within the meaning of this provision. Such a decision may call into question the validity of the equalization tax (précompte) due on certain dividend payments by French companies.

In the wake of a recent Supreme Court ruling, the reasonable taxation standard is clarified, and activities within the scope of the Irish IFSC regime are found to be comparable to activities within the scope of the Dutch GFC regime. By Daan de Bruin and Judy Chan Deloitte & Touche, International Tax Group, Netherlands

A tax appeal tribunal in the UK has ruled that a transfer pricing adjustment to income may be made to companies that set up and support share option schemes for employees of foreign subsidiaries. The Special Commissioners (the first level appeal tribunal on tax cases in the UK) held that share options provided on behalf of foreign subsidiaries were a business facility provided by the UK company to the foreign subsidiaries.

On January 1 2002, a number of tax amendments were approved by Congress following several months of analysis. The tax amendments had been subject to great debate, since it was intended to increase tax revenues by ending the value-added tax (VAT) exemption on a variety of items, especially food and medicines.

Efforts are made to phase out the extraterritorial income exclusion regime, anti-inversion legislation is proposed, and broad business purpose/economic substance standards are set. By Hal Hicks, David Benson and Margaret O’Connor of Ernst & Young, Washington DC

The UK government is being urged to improve the business environment by setting up an independent tax-setting body

The US Financial Accounting Standards Board (FASB) has named a senior PricewaterhouseCoopers partner as its new chairman, at a critical time for the profession

The Swedish and Danish operations of Andersen have agreed to join forces with Deloitte & Touche, in a further blow to KPMG