ITR Search | International Tax Review

Separating intangible value by surveys

In the ninth in a series of articles on intangibles and finance, Philip de Homont and Alexander Voegele of NERA Frankfurt show how to handle surveys for intangibles and transfer pricing.

July 12 2016

Tax Bill to have significant impact on financing transactions

As New Zealand proposes to revise its non-resident withholding tax rules and how they apply to interest, Shaun Connolly and Chris Harker of Russell McVeagh examine the implications for foreign and domestic parties to financing transactions.

July 12 2016

South Korea: Recent ruling clarifies whether foreign limited partnership can be looked through for purposes of treaty application

John Kwak Sang Jin Park The South Korean tax authority, along with the Supreme Court, have not always been in agreement on the way certain foreign pass-through entities are treated in foreign jurisdictions.

July 12 2016

Editorial

I join as the new editor of International Tax Review at a very exciting time.

Anjana Haines, July 12 2016

Russia: Companies must comply with new waste rules or face environmental tax

Andrey Ermolaev Many companies this year have fallen within the scope of new regulations on the disposal of consumer products and packaging waste.

July 12 2016

Chile: Entry into force regime for Chile’s General Anti-Avoidance Rule

Astrid Schudeck Jonatan Israel The interpretation of the General Anti-Avoidance Rule (GAAR) by the Chilean tax authority, concerning the entry into force of the provision, has been subject to strong criticism and confusion. This is because of conflicting interpretations of the rules and because the GAAR could apply to transactions performed before the entry into force date of September 30 2015 if the effects of the said transactions are generated afterwards.

July 12 2016

EU: Commission publishes working paper on state aid and tax rulings

Bob van der Made The European Commission (EC)'s Directorate General for Competition has published its working paper on state aid and tax rulings. It provides an overview of DG Competition's preliminary orientations after review of the member states' tax ruling practices.

July 12 2016

Switzerland: Swiss parliament approves Corporate Tax Reform III

Jacques Kistler Rene Zulauf The Swiss parliament approved Corporate Tax Reform III (CTR III) on June 17 2016. The main objectives of the reform are to align Swiss tax law with international standards and to enhance Switzerland's attractiveness as a location for multinational enterprises.

July 12 2016

Tax Relief

We all wish we could magic away our tax bills sometimes We all sometimes wish that we could wave a magic wand and make the tax go away – but Rupert Grint, who stars as Ron Weasley in the Harry Potter films, might have more reason to do so than most after taking the UK revenue authority, HMRC, to court in a £1 million ($1.3 million) dispute.

July 12 2016

US Inbound: Medtronic wins US transfer pricing case

Jim Fuller David Forst Medtronic is a recent and important US transfer pricing case. The case involved, among other things, the royalty rate payable by a Puerto Rican affiliate of the US taxpayer that produced medical device products.

July 12 2016

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