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The Taxand Quarterly
Focusing on the latest legislation and its implications for companies like yours—internationally and in local jurisdictions—the Taxand Quarterly provides finance directors, tax directors and other decision-makers with updates on the issues affecting you and your business.
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Introduction to our latest Taxand Quarterly (October 2008)
In this issue we firstly take a look at the key legislative changes affecting our clients across the world. In Germany the rules relating to tax based structures were strengthened. In Japan the Ministry of Economy, Trade & industry has recently announced its plan to push ahead with amending the international tax rules and repeal the taxation to which a Japanese parent company is liable on dividend income from overseas subsidiaries. In Luxembourg the 0.5% capital duty charge is to be abolished with effect from 1 January 2009. In Malaysia it has been announced that thin capitalisation rules are to be introduced and furthermore the scope of existing transfer pricing legislation is to be extended. In Romania, with effect from 1 January 2009 tax losses incurred as from the 2009 financial year and recorded in the annual corporate income tax return may be carried forward for the following seven years, whilst tax losses incurred before 2009 may be carried forward for the following five years.
We then move on to look at recent rulings and of particular note is the recent ruling in Portugal in relation to Advance Pricing Agreements. Court cases come next and the highlight this quarter is on the number of cases coming out of India : of particular note is the case relating to the attribution of profits to a dependent agent permanent establishment.
In "Other News" the highlight is the fact that the OECD has recently published the final version of its report on the attribution of profits to permanent establishments.
To end the tax update we have a number of special features with the one from the U.S. on Intangible Property and the two from the Netherlands focusing on the Netherland's competitiveness on the International stage being of particular interest.
And finally in the Taxand NEWS we take a look at what's been happening in Taxand recently including recent award news, client conferences, new members and the launch of our new Intranet.
Introduction Archive
Taxand Quarterly (July 2008)
In this issue we firstly take a look at key legislative changes affecting our clients across the world. In Belgium the tax authorities have published a circular on the application of the notional interest regime which in particular comments on the regime from the viewpoint of the general anti-abuse rules. In Finland the Government has published draft legislation which if adopted would narrow the scope of the CFC legislation. In Germany the draft 2009 Tax Act contains some important changes in tax law for inbound investors. In Luxembourg the Government has announced that capital duty will be abolished from 2009. In Russia the Government is currently discussing the main guidelines of Russian Tax Policy for 2009-2011 : there are several proposals that might influence multinational groups. In Puerto Rico the Economic Incentives Act for the Development of Puerto Rico has been introduced and includes tax incentives.
We then move on to look at recent rulings and of particular note is the recent ruling in India in relation to the taxability of intangible assets. Court Cases come next and as ever there a number of cases from the European Union - of particular interest is the case which found that the Spanish thin capitalisation provisions which have been in force since 2003 are contrary to EU Law.
To end the tax update we have three special features, one from each of Canada, Spain and the US. Of particular interest is the article from Canada which discusses the recent decision in the Prevost Car case which considered beneficial ownership of dividends - it is interesting to see the contrast between this case and the UK (non-tax) case, Indofoods.
And finally in Taxand NEWS we take at look at what's been happening in Taxand recently including providing an update on recent award wins, our global conference, the launch of new tools and our great performance in the ITR's online survey which ranked top tax advisory firms.