Search results for

KPMG Meijburg in Amsterdam has expanded its transfer pricing group by hiring a senior manager from PricewaterhouseCoopers. Eduard Sporken joins the firm on June 1. Sporken had not been thinking of leaving PricewaterhouseCoopers when KPMG approached him before Christmas. However, he was attracted to the opportunity to specialize in transfer pricing. He had also worked with KPMG in the past and knew people there.

The Dutch government has decided to issue a new proposal for measures against dividend stripping. Dividend stripping refers to a transaction in which a shareholder transfers its right to receive a dividend to another taxpayer prior to the declaration of the dividend. In most cases, the underlying reason is that the transferor is not in a position to offset the (Dutch) dividend withholding tax against personal or corporate income taxes, whereas the transferee is allowed to offset this tax.

Group treasury companies may be viewed as nothing more than a corporate moneybox or as in-house banks. Careful consideration of the circumstances is required. By Gareth Green, Ernst & Young, London

Recent developments in the US courts, the IRS, and the WTO and OECD are looked at in detail

The German Tax Reorganization Act in force since 1995 permits three types of divisive reorganizations – split-ups, split-offs and drop-downs – without triggering tax, provided two principal conditions are met: any unrealized appreciation (hidden reserves) inherent in the assets transferred must remain subject to German taxation; and the assets transferred – and for split-offs the assets retained as well – must constitute a branch of activity, an interest in a commercial partnership, or a 100% share in a corporation. The latter requirement poses many issues. Until recently, the tax authorities interpreted the key term "branch of activity" in such a way as to severely restrict the options available to taxpayers when structuring divisive reorganizations.

The UK has vetoed plans to introduce legislation on e-commerce taxation in the EU. The revised Swedish proposal would have made non-EU companies selling digitized products to EU consumers liable to value-added tax (VAT) on their sales. This would have levelled the playing field with their EU competitors who are already being charged VAT.

Romano Prodi, president of the European Commission, has called for a European tax to finance the EU budget

Nik Mehta, a tax partner at Linklaters, has qualified as a solicitor-advocate. This position allows him to represent clients in civil cases in the UK's High Court. Linklaters contentious tax group was set up last year and comprises tax and litigation lawyers. There are six tax lawyers in the group. While a number of the litigation lawyers are solicitor-advocates, Mehta is the first tax lawyer to be awarded the title.

Core competency and outsourcing are hot issues. The following article looks at why handing over non-core activities to the specialists can result in huge benefits for multinationals. By Sharon Cunningham

Like many other members of the OECD and the EU, Spain has enacted very few special tax provisions that apply to e-business. However, to clarify and fix its position in the various international forums where the taxation of e-commerce is being analyzed, in early 1999 Spain's secretary of state for taxes set up a working group whose remit was to conduct thorough research in this area. In July 26 2000, the group submitted its final report and an updated summary was released in October 2000. Two specific issues are of significance to foreign enterprises operating in Spain arising out of the preliminary position on the subject adopted by Spain that departs from current popular opinion.