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  • Attributing profits to a PE: a US perspective
    Determining the profits attributable to a PE is poorly explicated in practice. The OECD has drafted a proposal to clarify matters. By Philip R West, Andersen Office of Federal Tax Services, Washington, DC, and Robert Janukowicz and W Anne Jie, Andersen, New York
    June 30 2001
  • Russian uncertainty on beneficial ownership
    Foreign investors looking to use the beneficial ownership provisions of Russian tax treaties are up against a tradition of inconsistent application and poorly developed concepts. No guarantees are on offer, and the present round of tax reforms offers little hope for improvement. By Victor Matchekhin, Linklaters, Moscow
    June 30 2001
  • Belgium promotes employee participation
    Belgian companies wishing to motivate their employees through participation schemes now have the backing of the new Participation Law to facilitate their efforts. By Marc De Munter, Freshfields Bruckhaus Deringer, Brussels
    June 30 2001
  • Study group publishes white paper on future of Netherlands corporation tax
    The Study Group on Corporate Income Tax published a report June 11 2001, outlining its recommendations on possible amendments to the corporate tax rules to enhance the competitiveness of the Netherlands as a place to locate companies. The study group was set up after proposed changes to the Dutch tax system (eg application of the participation exemption and the tax treatment of hybrid instruments) were withdrawn so as to examine the Corporate Income Tax Act in a broader perspective.
    June 30 2001
  • New profits tax programme, and revisions to tax collection legislation
    "Assess first, audit later" programme introduced
    June 30 2001
  • Ormerod suggests UK rate cut to 25%
    In ?an open letter on eight priorities for British business? to Prime Minister Tony Blair, John Ormerod, UK managing partner of Andersen, has recommended that the UK corporate tax rate be reduced to 25%. The letter, dated June 12 says: ?Britain will lead the network economy world if we nurture the creation of new, innovative businesses and allow them to flourish.?
    June 30 2001
  • ITIO calls on OECD to demonstrate good faith
    The International Tax and Investment Organisation (ITIO) has warned the OECD to involve small countries properly in discussions or face the effective collapse of its ?harmful tax competition initiative?. With the OECD's Fiscal Affairs Committee due to spell out the future of the OECD's tax at the end of June, the ITIO is insisting that the OECD involve small and developing economies (SDEs) fully in the process of setting any new international standards.
    June 30 2001
  • India deregulates insurance, defers tax
    While the deregulation of India’s insurance industry is a welcome move, confusion over the tax aspects may prevent it from achieving its full potential. By Subhankar Sinha and Vijay Kumar, PricewaterhouseCoopers, Mumbai
    June 30 2001
  • Japan’s tokumei kumiai – still a versatile planning tool
    Tokumei kumiai arrangements continue to be a versatile planning technique for achieving a wide range of business and tax structuring objectives. This article looks at their use in Japan, and at the increase in tax audit scrutiny of TK arrangements. By Dean A Yoost and Todd Landau, PricewaterhouseCoopers, Tokyo and New York
    June 30 2001
  • Keeping the UK competitive
    As the UK’s Labour government is voted in for a second term of office, it is time to review the failures and gains of previous tax incentives, and take some bold steps to ensure future growth. Without some major changes, inward investors will go elsewhere. By Sian Sandeman and Heather Self, Ernst & Young, London
    June 30 2001
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