Search results for

SJ Berwin has established a Paris office by poaching a private equity team from Salans Hertzfeld & Heilbronn.

EU action on harmful tax competition has taken a significant step forwards. The rollback of measures with harmful features is now possible as early as 2002. By Heleen Nijkamp, chair of Ernst & Young’s EU Tax Steering Committee, New York

For foreign investors in Argentina, the question of whether business activities constitute a permanent establishment in the country is a crucial one. This special report outlines the definition, scope and practicalities of an Argentinian PE. By Daniel Albarellos and Horacio Dinice of Arthur Andersen, Buenos Aires

The US is to negotiate new tax treaties with Hungary and Australia.

The controlled companies provisions in Hong Kong's Estate Duty Ordinance were designed to counteract avoidance of estate duty. In general terms, a proportion of the Hong Kong assets of a controlled company would be deemed to be included in the property passing on the death of a deceased and chargeable to estate duty. However, the scope of the provisions was so widely drawn that it could catch many innocent transactions. On the premise that the provisions were not for generating revenue, the Inland Revenue Department reassures in its Interpretation and Practice Note, issued on December 21 2000, its policy that the provisions would only be invoked where there is patently an attempt to avoid estate duty.

Until recently most foreign investors making direct capital investments in Brazil were automatically protected against exchange losses. This was because the Brazilian Central Bank used to issue a foreign capital certificate guaranteeing that the original US dollar amount invested could be repatriated tax free as long as there was no deterioration of the company's net worth.

The US Internal Revenue Service has proposed new rules governing the opinions tax advisers are allowed to offer their clients with regard to tax shelters. By Keith Martin Chadbourne & Parke LLP, Washington

Tax reforms enacted during the time of economic boom are proving to be inappropriate in present-day China, which is still recovering from the difficulties of 1997 and contemplating accession to the WTO. As a result, the PRC government is now putting in place new reforms. By Matthew Mui and Ian Jia of PricewaterhouseCoopers, Beijing

The cover story in the April issue of International Tax Review will look at the online tax services offered by law and big five firms. We will look at the basic website and what kind of useful information firms are providing via this medium, through to high-end services such as online tax advice, client workspaces and portals.

On January 18 2001, Vietnam's Ministry of Finance issued the long-awaited circular clarifying the application of enterprise income tax to branches of foreign entities in Vietnam. The changes are effective February 1 2001. The circular increases the enterprise income tax rate applicable to foreign branches from 25% to 32% of taxable income. Taxable income for these purposes is defined as the total revenue of the branch less deductible expenses. Administrative expenses allocated from the head office to the foreign branch will be deductible, provided the foreign branch submits the audited financial statements of the head office to the local tax authorities. Royalty payments and commissions, including interest paid to a head office and interest payments relating to legal or chartered capital, may not be deducted. An exception to the non-deductibility rule applies to interest paid by foreign branches of banks.