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  • Constructive dividends from reduction of paid-in capital
    2001 tax reform
    August 31 2001
  • Asset Covered Securities Bill 2001
    Ireland has followed the lead of other European jurisdictions by proposing covered bond legislation based on the model of the German Pfandbriefe legislation. The Asset Covered Securities Bill is expected to be enacted into law in the last quarter of 2001.
    August 31 2001
  • Tax consolidation – actions against the 1999 tax reform programme
    In January 1999, Mexico enacted a tax reform programme that involved a number of adjustments to the tax consolidation regime.
    August 31 2001
  • Advance ruling
    The Authority for Advance Rulings (AAR) in India has issued a ruling (AAR No 442/1998) stating that gains realized on sale of shares of Indian companies, earned by a private equity fund (Fund) incorporated in Mauritius, will be regarded as business income and not capital gains.
    August 31 2001
  • P+P Pöllath + Partners
    Dr Matthias Bruse (Munich), partner Dr Thomas Töben (Berlin), partner Ralph Wagner (Frankfurt), partner
    August 31 2001
  • Court decision and France-Germany tax treaty
    Court decision: application of thin capitalization rules and tax treaties
    August 31 2001
  • Supreme Court decision on the classification of software as a literary work in the US-Spain convention
    Two Supreme Court judgments (dated April 28 2001 and June 9 2001) have, for the time being, ended the controversy in Spain over whether software falls within the category of a scientific or a literary work for the purposes of the US convention.
    August 31 2001
  • Interposed entity constitutes tax avoidance, says Australian High Court
    In its decision in Commissioner of Taxation v Consolidated Press Holdings of May 31 2001, the High Court of Australia held in favour of the Commissioner of Taxation, concluding that a financing arrangement in connection with a takeover bid for a UK company, involving the interposition of a subsidiary to obtain an interest deduction, constituted a tax avoidance scheme under Australian tax law. The High Court also decided on a dividend-stripping tax avoidance issue arising out of a subsequent corporate reorganization, this time in favour of the taxpayer.
    August 31 2001
  • Venezuelan Supreme Court decision grants certainty in reciprocal investments
    The Constitutional Chamber of the Supreme Justice Tribunal in Venezuela has dismissed the motion for nullity filed by attorneys Fermín Toro Jiménez and Luis Britto García against the agreement for the avoidance of double taxation between the US and Venezuela. The National Investment Promotion Council (CONAPRI) defended the action, with counsel from law firm Torres Plaz & Araujo.
    August 31 2001
  • German court vetoes document regulations
    A ruling by Germany's highest tax court in May of this year compels the German tax authorities to rethink their proposed transfer pricing documentation regulations. By Alexander Vögele and William Bader, KPMG, Frankfurt
    August 31 2001
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