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  • Taxing a Borderless world
    The OECD conference on e-commerce laid down basic principles and areas for debate. But, as Christine Sanderson of PricewaterhouseCoopers Global and Electronic Business Group reports, there is work still to be done for states to avoid the need for unilateral action
    December 01 1998
  • Denmark squares up for holding battle
    Competition for holding company business will intensify with the proposal for a new Danish structure. The regime offers multinationals significant benefits and, as Ned Shelton of Sheltons, Copenhagen, explains could win Denmark business from more established jurisdictions
    December 01 1998
  • Representative offices demand Customs amnesty
    The temporary importation of goods into the Russian Federation has become an increasingly problematic area for accredited representative offices of foreign entities. Many representative offices have goods which were imported on a temporary basis and are now reaching the end of their useful life. This raises the question of what should be done with these imported goods – and how much will it cost?
    December 01 1998
  • Discrimination against German Permanent Establishments of EU corporations
    In a ruling dated June 30 1997 (Saint-Gobain – IStR 1997, 557, with commentary by Dr Martin Lausterer), the Cologne Tax Court requested the European Court of Justice (ECJ) to decide whether various types of tax discrimination against the German permanent establishment of a foreign corporation resident in the EU are permitted under Article 52 of the EU Treaty (freedom of establishment).
    December 01 1998
  • Canary Islands: A tax landmark in Europe?
    Several aspects of the Canary Islands tax systems have traditionally differed from the tax regimes applicable in the Spanish mainland. In 1994 the tax regimes of these islands were adapted to modern tax systems with the entry into force of Law 19/1994, of July 6. This has subsequently undergone certain amendments.
    December 01 1998
  • New Tax Treaties
    The Portuguese parliament and the president have approved and ratified double tax treaties with the Czech Republic and Poland.
    December 01 1998
  • Growth of life insurance business
    The economic stability experienced during the last few years, together with greater interest on the part of individuals in this type of insurance, has accelerated the development of life insurance and related products, in Argentina. International corporations, aware of this development, have started to set up and compete in this new market.
    December 01 1998
  • New Tax Developments
    New government measures have just been announced in Brazil, as a result of the turmoil which engulfed the Brazilian economy last month.
    December 01 1998
  • Corporate tax reform; Switzerland-US tax treaty
    To increase the attraction of Switzerland as a holding location and a business headquarters site, various favourable tax reform measures were adopted by the Swiss parliament in October 1997. Except in the unlikely case of a referendum, the reform will probably enter into force as of January 1 1998. The most significant measures are discussed below.
    December 01 1998
  • Transfer pricing studies due by March 31
    Under the 1997 Mexican income tax reforms, all Mexican companies with international related-party transactions are obliged to document that their transfer prices were determined in accordance with the arm's-length standard. In particular, they must document that one of the transfer pricing methods specified by law has been employed.
    December 01 1998
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