Search results for

Spanish value-added tax (VAT) law makes the exercise of the right to deduct VAT borne before starting up activities conditional on the fulfillment of certain requirements (a formal pre-commencement of activities declaration must be filed: in practice, those activities charging VAT must be commenced within one year, or an application must be filed to extend such term). Failure to meet those requirements means a deferral of the VAT deduction until activities are actually started, and a consequent financial cost.

The £114 billion ($XX) agreement will create the world's largest pharmaceuticals group, with combined annual sales of more than £15 billion. The new company, Glaxo SmithKline, will control 7.3% of the world's drugs market. Glaxo shareholders will receive 58.75% of the new company's share capital, with SmithKline taking 41.25%.

Many Canadian non-residents with no permanent establishment in Canada might well anticipate that remuneration for services rendered in Canada should not be subject to withholding tax. The federal authorities do not agree and require a 15% withholding on fees, commissions or other amounts paid to a non-resident in respect of services rendered within Canada. (A further 9% Quebec withholding is required in respect of non-resident services rendered in that province.) If the non-resident is not subject to Canadian tax, they must apply for a refund by filing a Canadian tax return. If the non-resident is subject to Canadian taxation, the withheld amount can be applied to the non-resident's Canadian tax liability.

At present, in Ireland, there is a difference in the tax treatment of unit-linked investment products in the form of life assurance policies or mutual funds, dependant on whether they are available to Irish residents (Domestic Funds) or are exclusively available to non-residents (IFSC Funds). In the International Financial Services Centre (IFSC) where such products are sold exclusively to non-Irish residents, both the fund itself and the policy holders are exempt from Irish tax. In the case of such products outside the IFSC, however, Irish residents may be unitholders and the fund is subject to tax on an ongoing basis at the standard income tax rate of 24% (22% from April 6 2000).

Corporate tax

The following important tax developments have taken place in India.

Further to Australia's Review of Business Taxation, a number of capital gains tax changes became law from December 10 1999. Included in the measures are scrip-for-scrip rollovers and improved incentives for venture capital investment.

Nabisco and Hicks Muse, who are acting under the joint venture title Burlington Biscuits, are offering $3.97 for each United Biscuits share. If the offer is successful, Nabisco will also acquire United Biscuits' operations in China, Hong Kong and Taiwan. Although it is reported that the UK company has accepted the US offer, the French consortium Finalrealm has launched a £1.25 billion rival bid.

Bruno Gouthiere, of Bureau Francis Lefebvre, Paris analyzes the reasons for repatriating a Luxembourg captive reinsurance business back to France

Australia’s thin capitalization rules are covered in the wholesale tax reforms put forward in the Ralph Report. Peter van den Broek of Clayton Utz, Melbourne outlines the likely changes and their impact for international operations