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  • Compete as a qualifying intermediary
    Burdens imposed on non-US financial institutions by new US withholding rules can be alleviated by a qualified intermediary agreement with the IRS. By Barbara Hanrehan and Alan Shapiro of Deloitte & Touche, LLP New York and Washington, DC
    April 30 1998
  • Latin America builds bridges to investment
    Tax treaty negotiations in Latin America are proceeding at a rapid pace. Jorge Gross and John Salerno of Price Waterhouse LLP, Miami and Boston alert readers to the changes, and to the tax planning opportunities for multinationals
    April 30 1998
  • Canada unveils a new model system
    Canada’s Technical Committee on Business Taxation finds an uneven tax system at odds with development priorities and a highly taxed service sector. By Stephen R Richardson of Tory Tory DesLauriers & Binnington, Toronto
    April 30 1998
  • News in brief
    The OECD Council has adopted the recommendations of a study by the organization's committee on fiscal affairs on tax sparing. The study looked at the consequences of tax sparing provisions inserted into tax treaties. It showed that such provisions can give significant scope for tax planning and tax avoidance in both the country of the investor and the country of the investment.
    April 30 1998
  • The best advisers in Asia-Pacific
    Tax advisers thrive in periods of change. Financial instability in Asia has made more work for advisers, but brought greater pressure too. Clients demand lower fees and rivals try to poach staff. Phillippa Cannon and Adrian Preston discuss tactics with the winners and their clients
    April 30 1998
  • VAT TREATMENT OF ONLINE SERVICES
    In late 1997, the tax authorities released a new directive clarifying their views on the value-added tax (VAT) treatment of telecommunications and tele-services. As expected, the directive provides that tele-services are not identical to telecoms services, and hence are potentially subject to different VAT treatment.
    March 31 1998
  • MANAGEMENT, COORDINATION AND FINANCIAL CENTreS IN THE BASQUE COUNTRY AND NAVARRE
    Spanish tax legislation provides for various territorially-based special tax regimes, which in practice produce variations in the Spanish general tax regime. These special tax regimes, whose origins lie in historical considerations recognized and protected by the Spanish Constitution, specifically apply in the Basque Country's Ancient Territories (ie Alava, Guipúzcoa and Vizcaya) and in the Navarre Autonomous Community.
    March 31 1998
  • SHAM TRANSACTIONS REASSESSED
    A new decision on "turbo funds" sheds new light on the scope of the sham transaction procedure, as well as on the way the 80% penalty attached should apply (Tribunal Administratif d'Orleans – 1ère Chambre, December 9 1997 – req no 95-1535 – Société SDMO)
    March 31 1998
  • CUSTOMS DUTY AND VAT EXEMPTIONS REJUVENATED
    Import exemptions relating to customs duty and value-added tax (VAT) were reintroduced on January 1 1998, following their abolition in April 1996. However, only a relatively small group of foreign investors will now qualify for the exemptions.
    March 31 1998
  • BUDGET MODIFIED INTERNATIONAL TAX RULES
    Canada's government unveiled its new budget on February 24. Many measures modify international aspects of Canada's tax system and will generally apply after the 1997 taxation year.
    March 31 1998
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