ITR Search | International Tax Review

German court bans secret comparables

The Düsseldorf Regional Tax Court has prevented tax auditors from using secret comparables in transfer pricing studies. The decision also raises questions over the use of profit methods. Thomas Borstell and Michael Prick, Ernst & Young Düsseldorf, examine the decision

March 31 1999

Budget updates

South Africa

March 31 1999

Colombian disasters squeeze tax

A series of economic and geological crises have forced the Colombian government to expand the tax base through income tax and VAT changes. Publio Perilla of Gomez Pinzon & Asociados in Bogota explains the consequences for multinationals

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

US case law: the rulings that count

In a busy year, the US tax courts ruled on subjects ranging from foreign tax credits to related party borrowings. Daniel Berman and Jeffrey Korenblatt, Sutherland Asbill & Brennan LLP, Washington DC analyze the rulings and their consequences

March 31 1999

Centros Ltd and Erhvervs-og Selskabsstyrelsen

Freedom of establishment – Establishment of a branch by a company not carrying on any actual business – Circumvention of national law – Refusal to register.

March 09 1999

Russian Tax Code

Part I of the Russian Tax Code became effective on January 1 1999. It introduced a number of developments in personal income tax legislation, which will affect expatriates working in Russia as well as local staff. The main provisions are outlined below, but it should be noted that the legislation is probably more remarkable for what it did not include.

March 01 1999

The vis attractiva

The use of the so-called vis attractiva (literally power of attraction) highlights the link between the concepts of income and residence. It might be used to attribute foreign income profits to substantially Italian tax resident individuals who are formally resident abroad.

March 01 1999

Publication of Finance Bill 1999

Ireland's minister for finance has published his Finance Bill which runs to a weighty 326 pages. The following are some of the principle features outlined in the Finance Bill.

March 01 1999

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