ITR Search | International Tax Review

Spain suffers APA teething problems

The Spanish APA system was established three years ago, and has achieved some success. Amalia Gracia and Joaquín Velasco of Ernst & Young in Madrid discuss the difficulties faced so far and suggest ideas for improvement

March 31 1999

Freshfields gives focus to ex-Sidley partner

Freshfields' New York office has attracted another tax partner from a top US law firm, just months after recruiting Gregory May from Milbank Tweed.

March 31 1999

Getting, having and holding

The attractions of a career in industry are increasingly challenged by the big five who are beginning to market themselves as equally benevolent employers. Rosie Murray-West finds out what it takes to get and keep a top tax team

March 31 1999

Belgium revamps stock options

The Belgian parliament has approved radical changes to the taxation of stock options. The changes could make stock options more attractive to both businesses and their employees. The decision follows months of debate between tax professionals and the revenue authorities.

March 31 1999

Drug companies swallow Japan’s bitter pill

Swiss pharmaceutical manufacturer Novartis is the latest company to feel the wrath of the Japanese authorities over transfer pricing. The Japanese government has fined Novartis' Japanese subsidiary, Ciba-Geigy Japan, ¥3.3 billion ($28 million) for underreporting its income by ¥8 billion between 1990 and 1994.

March 31 1999

Budget updates

United Kingdom

March 31 1999

Japanese APAs hit their stride

The Japanese preconfirmation system has been around for 12 years – longer than even the US system. Akio Miyamoto, Dean Yoost and Greg Noble of PricewaterhouseCoopers in Tokyo discuss the system and the increasing popularity of bilateral APAs

March 31 1999

Reaping the benefits of US secondment

Sending employees to the US has become a necessity for many multinationals, requiring careful planning of income tax and social security contributions. John Brantley and Doug Oas of Deloitte & Touche in London examine the opportunities available

March 31 1999

Further amendments to the Canadian imputation rules

On March 10 1999, the Canadian government tabled a revised, detailed Notice of Ways and Means Motion modifying, in certain respects, the proposals relating to section 17 of the Canadian federal Income Tax Act contained in an earlier Motion tabled on December 10 1998 (see International Tax Review, March 1999).

March 31 1999

Tax grouping possible with non-UK companies

Following the European Court of Justice's judgment in ICI v Colmer, the UK Inland Revenue has said that claims for group and consortium relief will now be accepted between UK-resident companies where a group or consortium is established by reference to companies resident in the European Union (EU) or the European Economic Area (EEA).

March 31 1999

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