Search results for

General anti-avoidance rules fill tax advisers the world over with trepidation. With good reason? Oliver Ralph compares practices and precedents across international jurisdictions, to discover the substance behind the rules

Senior German tax officials responsible for Germany's international tax policies have consistently stated in public that comparable profit methods and transactional net margin methods will not be accepted by the German tax authorities, and that profit splits are only acceptable in rare instances as a method of last resort. They have also frequently expressed their opposition to US-style economic analysis and voiced serious reservations concerning Advance Pricing Agreements (APAs).

Most large Mexican business taxpayers must have their annual tax returns certified by a public accountant. Other taxpayers may do so on a voluntary basis as a shield against a government tax audit. For calendar year taxpayers required to have an accountant's report (dictamen fiscal), the tax return is due on March 31 and the dictamen fiscal on July 31.

Germany has inaugurated a new era of opportunities for shareholder buybacks. Wolfgang Oho and attorney at law Günther Bredow, of Pünder, Volhard, Axster & Weber in Frankfurt, examine the balance sheet and fiscal considerations

European Monetary Union (EMU) will affect the European group on two levels – structural and technical. Ernst & Young’s international tax group London examines some of the most striking of the structural business effects, and highlights technical pitfalls.

In an international context, making use of different classification rules for debt and equity can create hybrid financing instruments. Harry Doornbosch and Allert Kramer, PricewaterhouseCoopers, New York look at the hybrid options from a Dutch perspective

The foreign tax credit treatment of UK ACT in the US continues to be a thorny issue for many taxpayers. Lawrence A Pollack, KPMG New York, David Porter and Frances Corrie, KPMG London examine the pieces of the puzzle and suggest solutions

It has been a month in the news for KPMG. Between advertising campaigns and plans to float part of the partnership, the global services firm has rarely been out of the headlines. KPMG has now announced that it is to spend $60 million on a brand building campaign. It will be based on the phrase ?It's time for clarity?. The inspiration for this gem comes from a survey of 250 chief executive officers and chief financial officers at Fortune 1000 companies. The respondents expressed concern about the information overload and confusion of advice they receive.

The UK government has abandoned a plan to increase taxation of the oil and gas industries. In the March 1998 budget, chancellor Gordon Brown announced his plan to begin consultation on the possibilities for change. But, after months of uncertainty, the plan has been dropped. Brown put the change of heart down to oil prices. ?I have concluded that at the current low level of oil prices it would not be right at this stage to proceed with reform of the regime,? he said.

UK mutual insurance company Friends' Provident is to buy London & Manchester, a life insurance company. The deal is valued at £750 million ($1.2 billion) and will make Friends' Provident the UK's fourth-largest mutual life insurance company.