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UK corporation tax receipts were lower at the end of the 2007-2008 financial year than the previous year, before the economic downturn hit the country, a report has found

The rules for the UK taxation of securitisation companies are now being used by structures specifically created, or suffering, during the economic downturn, explain Sean Finn and Graham Samuel-Gibbon of Latham & Watkins

Modelling techniques can help to estimate the probabilities of uncertain tax positions under IAS 12, believe Rutger Hafkenscheid and Claudia Janssen

Broad changes including the reform of crucial deferral rules are on the way for corporate taxpayers if the budget proposals announced by President Obama make it into final legislation

Firms that are adapting better to the changed economic circumstances, are showing their worth in International Tax Review's second annual poll to find the leading transactional firms around the world

By Jack Grocott

Thomas Pippos On February 4 the new National led centre right government announced a number of initiatives to help stimulate economic activity.

Roberto del Toro Mario Alberto Gutierrez The provisions of the Iceland-Mexico income tax treaty, which was signed in Mexico City on March 11 2008, apply from January 1 2009. Mexico's official gazette on December 11 published the Mexican Senate's authorisations of Mexico's tax treaty with Iceland and the text of the treaty itself on December 31 2008. The treaty not only covers the Mexican income tax, but also, the new Mexican flat tax (IETU). Some of the main provisions included in the treaty are:

Rajendra Nayak Ganesh Pai The Pune Income Tax Appellate Tribunal (ITAT) in the case of Epcos AG (2008-TIOL-47-ITAT-PUNE) recently examined whether the activities of Indian subsidiaries constituted a permanent establishment (PE) for its parent in India. The taxpayer, a company incorporated in Germany, was engaged in the business of designing, manufacturing and marketing electronic components. It had two Indian subsidiaries which were engaged in the manufacture and sale of electronic components to customers in India. The taxpayer provided certain services to its Indian subsidiaries through its central marketing and IT support teams from outside India.

Alke Schröder As a first reaction to the financial crisis in 2008 Germany enacted the Finanzmarktstabilisierungs-fondsgesetz (FMStFG) with effect from October 18 2008 to establish a state fund to guarantee bank deposits and other liabilities and so stabilise the German financial market. However, banks taking advantage of the umbrella have to accept various conditions, including the state as a shareholder. The share transfer or capital increase which this involves could lead to curtailment of the loss carry-forwards of the bank, or of one of its subsidiaries, under sec. 8c of the Corporation Tax Act, which curtails the loss carry forward on transfer of more than 25% of the share capital to a single immediate or ultimate shareholder. The FMStFG exempts German banks from this loss relief curtailment both on the original state acquisition and on the subsequent reprivatisation.