Título de la Revista: INTERNATIONAL TAX REVIEW
Año........................:2004
Número..................:9
Volumen................: 15
INSTRUCCIONES PARA PEDIR COPIA DE UN ARTICULO
Comment, 3
The new ECJ - has their approach changed?
By Peter Cussons, international corporate tax partner, PricewaterhouseCoopers, London
News, 4
Tax lawyers claim privilege against UK disclosure rules
Tax breaks for UK film industry get cool response
New EU members reject criticism of corporate tax rates
Korb promotes US APA process in Europe
Manninen is another blow for national tax
IRS rejects tax lobby act
UK and Indian companies to benefit from changes to tax dispute procedures
Who's worked on the biggest deals
In brief, 5
EU calls for aviation fuel tax
India gives its final word on the taxation of business process outsourcing
European Commission heads off future scandal with corporate tax strategy
China publishes APA implementation rules
Peru introduces new taxpayer registration rules
Ireland's holding company regime is legal
People and firms, 8
New Zealand accounting firms' tax advice to be legally privileged
Cuatrecasas hires tax group in Portugal
Baker & McKenzie expands UK tax practice
Law firm sets up new tax practice in Austria
News in brief, 9
PricewaterhouseCoopers partner jumps ship for US law firm
Senior French government tax adviser moves into private practice
Deloitte loses legal link in Poland
Coudert Brothers adds French tax partner
IRS litigator moves to Greenberg Traurig
White & Case snaps up former Commerzbank tax specialist
Dorsey & Whitney beefs up tax litigation
Cover Story, 11
Corporate tax harmonization moves up the EU agenda
Adam Craig of Deloitte in London analyzes the potential and progress-to-date of harmonizing corporate taxes in Europe
Features, 14
US
How to make transfer pricing work for IP and intangible assets, 14
Taxpayers must recognize the value of IP and use the correct valuation method for it, believe Weston Anson and Chaitali Ahya of Consor Intellectual Asset Management
Germany
Thin-capitalization amendments affect financing arrangements, 17
Domestic companies are now subject to thin-capitalization rules in Germany. Taxpayers should examine each structure before deciding whether to take steps to comply with the changes, urge Ralph Dautel, Jochen Murach and Alexander Pupeter of P+P Pöllath + Partners
Austria
Government tries for more investment with corporate tax changes, 21
Austria's corporate tax reforms introduce wide-ranging changes, including a tax rate reduction, explain Christian Hoenig and Niklas Schmidt of Wolf Theiss
UK
The benefits of merging the UK's tax administration, 25
Bringing together the two departments responsible for the administration of direct and indirect taxes has great potential for improving tax administration in the UK, believes Richard Highfield of the OECD
Brazil
Government continues reform of system of social taxes, 28
The PIS and COFINS taxes have been extended to include the importation of goods and services. Taxpayers need a detailed knowledge of where the new charges apply, warns Roberto Haddad of Branco Consultores
Hungary
Tax regime compensates for the end of offshoring, 33
Hungary's favourable tax regime for offshore companies ends in 2005. But the country's tax system will still be attractive to international business, believe Jacques de Servigny and Orsolya Bárdosi of Gide Loyrette Nouel
South Africa
Government bids to amend Secondary Tax on Companies, 38
Non-discrimination is at the centre of taxpayers' claim for an exemption from the Secondary Tax on Companies in South Africa. The government plans to stop them succeeding, reveal Anne Bennett & Nola Brown of Deloitte Touche Tohmatsu
Netherlands
Revised decrees clarify APA rules, 40
The Netherlands has updated its APA rules. Dave Rutges, Eduard Sporken and Kelly Bouman of KPMG Meijburg & Co discuss what this will mean for corporate taxpayers
International Updates, 43
Australia - The focus of the new compliance programme
European Union - ECJ facilitates acquisitions of Belgian target companies
France - Cases clarify inter-company aid
Germany - Manninen: creditability of foreign corporation tax
India - When agent residence constitutes a permanent establishment
Italy - New international ruling procedure becomes effective
Japan - Reducing capital can reduce local tax consequences
Mexico - What the tax reform proposals offer
South Africa - Why the participation exemption falls short
Spain - Reporting obligations for preferred shares and debt instruments
Switzerland - New benefits under the EU Directives
UK - What the Manninen case means for UK taxpayers
US Inbound - Proposed reorganization regulations make planning mergers even easier
US Outbound - IRS issues proposed stapled stock regulations
PARA ENVIAR PETICION: 