ITR Search | International Tax Review

Transfer pricing ruling; Permanent establishments, residency, capital gains tax and double tax agreements

The Australian Taxation Office (ATO) has recently released a taxation ruling (TR97/20) which explains the acceptable arm's-length methodologies that Australian taxpayers must use for their international dealings.

December 01 1998

Decisions of the highest courts significantly reduce corporate tax burdens

Supreme Court overrules legality of certain tax resolutions passed by the Kirienko government

December 01 1998

Collective investment offshore funds; Cyprus double tax treaty with Russia

Collective investment funds or mutual funds have been around for a long time. They offer the opportunity to investors, large and small, who may or may not be acquainted with investment techniques, to pool their funds with the primary aim of spreading their investment risk and obtaining stronger purchasing power. A collective investment fund can either be a close-ended or open-ended fund.

December 01 1998

General Electric and Lockheed Martin tax-free exchange

General Electric and Lockheed Martin have agreed to a tax-free exchange. General Electric will exchange its holding of Lockheed Martin preferred stock, and some non-core businesses, in return for a wholly-owned subsidiary of Lockheed Martin. The subsidiary owns Access Graphics, LM Aerostructures, and an equity stake in telecommunications service provider, Globalstar.

December 01 1998

Recovery of VAT in Spain before starting activities

A Spanish court recently referred a question to the European Court of Justice (ECJ) for a preliminary ruling. At issue was the Spanish system for recovering input value-added tax (VAT) incurred prior to starting business activities; the system has traditionally been a bone of contention between the tax authorities and VAT payers.

December 01 1998

Consolidated Press Holdings Cases – Deductibility of Funding Costs of International Business

The recent decision of Australia's Federal Court in two cases involving companies within Kerry Packer's Consolidated Press Group have provided guidance for Australian taxpayers structuring overseas investments, including consideration of the deductibility of funding costs of international business. It should be noted that the decisions are subject to appeal.

December 01 1998

UK unwraps GAAR proposals.

After months of speculation, the UK government has released a consultative document on a GAAR. In a follow-up to last year’s article on the subject, Peter Nias of McDermott, Will & Emery, London argues that this could lead to excessive power for the courts and the Revenue

December 01 1998

Exploring options in Germany

Stock options, an increasingly popular means of aligning employee remuneration with company performance, are now becoming more widely available in Germany. Sven Tischendorf, Wessing & Berenberg-Gossler, Frankfurt discusses their tax and other implications

December 01 1998

Irish budget slashes business taxes

The Irish budget for 1999/2000 has promised tax cuts across the board as the government deals with excess revenue provided by the country’s sustained economic boom. The proposals include a cut in the corporate income tax rate of four percentage points to 28%. There are also benefits for personal taxpayers in the form of changes to income tax bands and increased allowances.

December 01 1998

Japan makes new cuts.

Japanese Prime Minister Keizo Obuchi and opposition party leader Ichiro Ozawa have agreed to increase the scale of tax cuts from Y6,000 ($50.5bn) to Y10,000 ($84.2bn). The cuts are aimed at stimulating the flagging economy by encouraging spending.

December 01 1998

Search results for