Search results for

Successfully buying into a Japanese business turns on a complex interaction of acquirer, target and seller considerations. Dean Yoost, Takuro Tagai and Al Zencak of PricewaterhouseCoopers, Tokyo detail the most important issues

Deloitte & Touche has recruited John Lyons, formerly a top executive at the Internal Revenue Service (IRS), as global director of its Competent Authority Practice based in Washington. One of Lyons' principal responsibilities is to expand the Competent Authority Practice by recruiting tax treaty and transfer pricing professionals around the world.

Saudi Arabia has introduced a new set of tax incentives for foreign investors. The new regulations, which were announced on April 11, will lower profits tax from 45% to 30%, with foreign profits below $26,670 being taxed at 25%. The carry-forward of losses will be allowed for the first time.

The German Tax Supreme Court has just published two landmark decisions strictly limiting the application of general anti-abuse or substance over form provisions.

Slaughter and May's London office is acting for Abbey National. Corporate partners Tim Clark and David Whittman are heading the team with tax advice from tax partner Steve Edge and assistant Gillian Wheeler.

Germany's highest tax court has rendered a fundamental decision on the tax treaty treatment of income from a so-called "atypical silent participation". In response to the court's holding that such income is to be treated like income from a partnership interest, the tax authorities gave notice of their refusal to acquiesce in the judgement.

Indonesia has shocked foreign companies based on the island of Batam by scrapping exemptions from luxury goods tax and value-added tax (VAT).

Clear Channel asked Texas-based Akin, Gump, Strauss, Hauer & Feld to act on the deal, with partner W Thomas Weir and associate Scott Stewart providing tax advice.

The revenue authorities in Mumbai had previously disallowed a number of benefits of the tax treaty between India and Mauritius to certain investment funds based in Mauritius, on the basis that these entities were established in Mauritius purely for the avoidance of Indian taxes and for treaty shopping. This conclusion was reached based on an analysis of the operating structure of the relevant Mauritius-based funds.

land's Finance Act 2000 has fundamentally changed the tax treatment of funds in Ireland. It attempts to homogenize the tax treatment between investment funds previously available to Irish residents (domestic funds) and those which were only available to non-Irish residents. In so doing, the new regime deals with some EU concerns and especially Spanish discontent at the alleged discriminatory treatment of the previous regime. The changes should further enhance Ireland's attractiveness as a base from which to conduct investment fund business and provide Irish investors with a new attractive investment vehicle.