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  • Why the US-Luxembourg treaty brings long-awaited benefits
    The US-Luxembourg treaty has finally coming into force. The following article explains why multinationals can look forward to a period of stability. By Phil Warner, Ernst & Young’s International Tax Services group, Birmingham, and David Allgaier, Ernst & Young’s US Tax Desk, London
    September 30 2001
  • Thai withholding rules fail to address overpayment process
    Thailand has introduced a new domestic withholding tax regime from July 16 2001 onwards. The key objective of the new law is to expand the scope of withholding tax by subjecting most elements of income to the tax, with the exception of the sale of goods, which is not covered by the new law. This is consistent with the Thailand tax authorities' new tax collection efforts that were introduced earlier this year.
    September 30 2001
  • Latham broadens European offering
    Latham & Watkins and Stibbe Paris have combined, effective October 1, giving the firm 95 lawyers in Paris and more than 200 attorneys throughout Europe. The combined firm will be known as Latham & Watkins.
    September 30 2001
  • Mexican taxation of mergers and spin-offs – proposed changes
    Under the Mexican Federal Fiscal Code (MFFC), in the case of a merger or spin-off, the transfer of ownership of stock or goods is considered a taxable event, unless certain requirements are met.
    September 30 2001
  • Letter from the editor
    International Tax Review, in association with KPMG, hosted its first Transfer Pricing Forum in Amsterdam on September 10 and 11. On the table for discussion were topics such as intangibles and intellectual property, e-commerce, APAs and dispute resolution, OECD and national developments, and practical transfer pricing strategies. The speaker line-up incorporated representation from in-house tax groups, professional advisory firms and law firms as well as the OECD.
    September 30 2001
  • Boeing R&D decision creates split among US courts of appeal
    Creating a split among the US courts of appeal, the Ninth Circuit, in Boeing Co v US, validated Treasury Regulations section 1.861-8(e)(3) when it held that total research and development (R&D) costs must be allocated against export sales in computing the combined taxable income (CTI) of a FSC or DISC. The Boeing decision means that the appeals courts have now ruled once in favour of, and once against, taxpayers with regard to the proper allocation of R&D on unsuccessful or unexported products.
    September 30 2001
  • Spain to reduce telecoms taxation
    The Spanish government is cutting a tax on third-generation (3G) mobile phone operators by 62.5%, in response to industry lobbying
    September 29 2001
  • New Ernst & Young team to target entrepreneurial business
    Colin Masters has left his senior role at Coutts & Co to head a new Ernst & Young team, which will target entrepreneurial business with a variety of tax planning services
    September 29 2001
  • Tax exemptions lower Israeli venture capital barriers
    The Israeli government is scrapping capital gains tax on foreign investments in local venture capital funds, following concerns about the disincentive that the former double taxation system created
    September 29 2001
  • LatAm gas pipeline pact to spur investment
    Investors are to benefit from a more liberalized Latin American energy market after regulators signed a pact guaranteeing equal treatment for both foreign and local companies
    September 29 2001
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