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Stories that are tagged 'group taxation'

EU Parliament Backs Mandatory CCCTB
4/26/2012
The European Parliament has voted in favour of making mandatory the implementation of a Common Consolidated Corporate Tax Base among European Union member states despite sustained opposition from some nations.
India Reassures US On Retrospective Tax Plans
4/24/2012
India's Finance Minister Shri Pranab Mukherjee has defended plans for retrospective tax legislation, telling the US Secretary of the Treasury that the proposals merely clarify the intent of current laws.
Vodafone Challenges Indian Tax Law
4/23/2012
The ongoing tax dispute between India and Vodafone has erupted again, with the telecoms company now serving a Notice of Dispute against the government's controversial new retrospective tax legislation.
No New Taxes In Budget For Canadians
3/30/2012
The Canadian government has left tax rates on hold for another year in the 2012 Budget, announced by Finance Minister Jim Flaherty on March 29.
OECD Forum To Simplify Transfer Pricing Rules
3/30/2012
Meeting at the first Organization for Economic Cooperation and Development Global Forum on Transfer Pricing, tax officials from 90 countries agreed on the need to simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution.
IRS Reorganizes Advance Pricing Procedures
3/29/2012
The United States Internal Revenue Service has announced organizational and administrative changes and transitional procedures in connection with the creation of the Advance Pricing and Mutual Agreement programme.
Australia To Amend Transfer Pricing Regime
3/21/2012
The Australian government has released draft proposals that will launch the first stage of its reform of the transfer pricing system.
Vale Posts Brazilian Back Tax Case Collateral
3/12/2012
Vale, the world's second largest mining company, has clarified that despite being required to pay USD915m in judicial deposits, it remains confident of a favourable ruling in the tax case with Brazilian authorities over back taxes, worth BRL25bn (USD13.9bn) as it continues to pursue all legal avenues.
Sarkozy Seeks Minimum Tax For CAC 40 Groups
3/12/2012
Determined to refute claims by the left-wing opposition that he is ‘the president of the rich’, in the run up to the presidential elections, French President Nicolas Sarkozy has recently put forward the idea, if elected, of introducing a minimum tax on the profits of large ‘international’ companies listed in the CAC 40, the French stock index.
Ireland Unveils New Tax Incentives
2/17/2012
Tax reform features heavily in Ireland's new Action Plan for Jobs, a package designed to boost job creation and establish Ireland as the best small country in which to do business.
Vale Scores Victory In Brazilian Tax Appeal
2/1/2012
Vale, the world's second largest mining company has won an injunction in a long-running court battle against the Brazilian tax authority relating to claims for billions of dollars in back taxes said to be due on its foreign-sourced income.
Austria Focuses On Eradicating Tax Loopholes
1/23/2012
Echoing views expressed in parliament recently by Austria’s Finance Minister Maria Fekter, legal tax expert Werner Doralt has given his full support to any plans to close existing loopholes in the country’s tax system to consolidate the budget.
France, Germany To Act Swiftly On Tax Convergence
1/20/2012
France and Germany have pledged to put forward concrete proposals for a common corporate tax base by the end of February, in a joint document outlining their strategy for exiting the crisis and for strengthening growth.
Obama's Job Council Recommends Tax Reform
1/20/2012
President Barack Obama's Council on Jobs and Competitiveness, set up a year ago, has presented its 72-page report, including recommendations to create a simpler, more efficient tax system that 'levels the playing field for businesses and makes the US more competitive internationally'.
Luxembourg Discusses Tax With Danish Presidency
1/19/2012
Luxembourg’s Finance Minister Luc Frieden has recently conducted a working visit to Copenhagen for bilateral discussions with Denmark’s Economic Affairs Minister Margrethe Vestager and with the country’s Finance Minister Bjarne Corydon, with the talks focussing in particular on taxation and on financial regulation.
Austrian Businesses Slam Chancellor's Tax Rise Plans
1/18/2012
A recent survey of 1,300 businesses, conducted by the Austrian Economics Chambers in the regional province of Steiermark, has revealed that 95% of those companies surveyed are in favour of budgetary consolidation by means of expenditure-based measures, while only 17% support the idea of wealth-related taxes as a means to cut the country’s deficit.
Austria Mulls Wealth-Related Taxes In EUR10bn Package
12/29/2011
Following intense discussions, Austrian Chancellor Werner Faymann and Vice Chancellor Michael Spindelegger recently united on plans for a five-year budgetary consolidation package, amounting to a total volume of around EUR10bn (USD13bn), to be agreed by the end of February following careful examination of both expenditure-based and revenue-based measures.
CFCs To Benefit From New UK Tax Regime
12/8/2011
A major overhaul of the UK's controlled foreign company rules has been welcomed by tax experts, who conclude that the proposed new regime will go a long way towards changing the negative perceptions of the UK's corporate tax regime among multinational businesses.
Brazilian Court Dismisses Vale's Tax Appeal
12/5/2011
The world's second largest mining company, Vale has been unsuccessful in appealing back taxes said to be due on its foreign-sourced income.
Australian Tax Changes Target Consolidated Groups
11/30/2011
The Australian government has decided to introduce changes to income tax law affecting consolidated groups. The changes relate to the way a consolidated group can deduct the costs allocated to some assets following a corporate acquisition.
Sweden To Tighten Interest Deduction Rules
11/21/2011
The Swedish government has announced plans to set up a corporate tax committee tasked with examining the issue of questionable, ‘aggressive’ tax planning in the private healthcare and education sectors with respect to interest deductions.
South Africa Clarifies Takeover Debt Taxation
11/21/2011
South Africa’s Minister of Finance, Pravin Gordhan, in his introductory remarks to parliament on the Taxation Laws Amendment Bills, 2011, clarified the final disclosure requirements under the anti-avoidance rules within the country’s tax code that were originally introduced to facilitate intra-group transactions.
OECD Reviews Transfer Pricing Rules On Intangibles
11/21/2011
The Organization for Economic Cooperation and Development has noted the progress made by its Working Party and private sector representatives on definitional and ownership issues related to transfer pricing for intangibles as defined by the OECD Transfer Pricing Guidelines.
Austria Insists FTT Would Support Growth Measures
10/24/2011
During a recent European Union committee meeting in parliament, Austrian Chancellor Werner Faymann once again reaffirmed his commitment to the introduction of a financial transactions tax, underscoring that the levy would serve to create scope for growth-enhancing measures.
Austrian Businesses Welcome ÖVP Tax Plans
9/29/2011
President of the Austrian Federal Economic Chamber Christoph Leitl has welcomed the fiscal plans unveiled by Austrian Finance Minister Maria Fekter and by Economy Minister Reinhold Mitterlehner.
Austrian Vice Chancellor Rejects Wealth Tax
9/20/2011
Austria’s Vice Chancellor and leader of the Austrian People’s Party Michael Spindelegger recently insisted that the idea of introducing wealth taxes or reintroducing inheritance tax in Austria is simply out of the question.
Liechtenstein Extolled As 'Attractive' Tax Location
9/15/2011
In a recent article, KPMG Switzerland praises the principality of Liechtenstein, describing the state as ‘an attractive tax location' for both German and Swiss businesses, following entry into force of its new tax law on January 1 of this year.
South Africa Looks At Headquarters Company Regime
9/14/2011
While, last year, the National Treasury proposed a new initiative, intended to make South Africa a more attractive base for investment into other African countries by both domestic and foreign investors, taxpayers have raised concerns over the approach of the South African Revenue Service to its headquarters company tax regime.
Austria's SPÖ Unveils 5 Point Fiscal Plan
9/13/2011
Austria’s Chancellor Werner Faymann and Financial State Secretary Andreas Schieder recently unveiled details of the Social Democrat’s five-point fiscal programme, seeking greater equality of wealth distribution in Austria, and containing plans for the introduction of a millionaire’s tax on private wealth in excess of EUR1m.
OECD Concerned At Corporate Tax Loss Abuse
9/5/2011
The Organisation for Economic Cooperation and Development has released a new report to aid governments in tackling the use of aggressive tax planning used to artificially create or boost companies' losses for tax mitigation purposes.
James Hardie Wins Large Back Tax Appeal
8/24/2011
James Hardie Industries has successfully appealed against a huge tax bill handed out by the Australian Tax Office in relation to a corporate restructuring which took place over a decade ago.
Australia Tackles Uncertain Tax Rules
7/6/2011
The government has said it has enlisted tax experts to help clarify uncertainty surrounding the 'consolidation rights to future income and residual tax cost setting rules', which were reviewed in 2010.
South Africa Consults On Intra-Group Tax Rules
7/5/2011
The South African Revenue Service and the National Treasury have announced an accelerated consultation process on proposed anti-avoidance measures to be inserted into the 2011 Taxation Laws Amendment Bill, intended to ensure the free movement of tax-neutral assets between members of a corporate group.
Schäuble Eschews Tax Cuts
6/7/2011
During a recent address at the German tax congress in Berlin, Germany’s Finance Minister Wolfgang Schäuble re-emphasized that there is currently no scope for large-scale tax reform and for dramatic tax cuts in Germany.
BHP Billiton Wins Lengthy Tax Credits Case
6/7/2011
The High Court of Australia has upheld the ruling of the Federal Court that BHP Billiton properly applied the arm's length principle in writing off debt accumulated by its financing subsidiary from a loan provided to an ill-fated subsidiary formed to undertake an iron ore project in Boodarie, Western Australia. As a result of the ruling, the mining giant can now claim AUD554m (USD580m) in tax credits.
UK CFC Rules Still Break EU Law
5/23/2011
The UK must amend its legislation on the tax treatment of controlled foreign companies, as it fails to fulfil European Union Treaty obligations or adequately take into account relevant court rulings, the European Commission has said.
OECD Praises Russian Transfer Pricing Changes
5/19/2011
Amendments to Russia's transfer pricing rules, designed to improve efficiency and reduce tax avoidance, have been welcomed by the Organization of Economic Co-operation and Development, which says such changes would bring them largely in line with international standards.
India Gears Up For Transfer Pricing Changes
5/17/2011
Tax experts in India have called for the country’s transfer pricing system to have in-built mechanisms for smooth negotiation and conflict resolution, as radical changes are underway for the Direct Tax Code, most likely coming into effect from April 1, 2012.
UBM Considering Return To UK
4/22/2011
United Business Media could relocate back to the UK in the coming months, its chief financial officer has hinted.
IBM Loses Australian Transfer Pricing Case
4/19/2011
IBM has lost a AUD55m federal court case against the Australian Tax Office, a decision which could have major ramifications for other technology companies operating in Australia.
Germany Plans Cross-Border Loss Relief
4/6/2011
Bowing to pressure from the European Commission, the German government is believed to be planning to introduce a new tax break, designed to reduce the burden on German companies by enabling losses incurred by subsidiary companies established abroad to be offset against the profits of the parent company based in Germany.
Puerto Rican Tax Deductible In US, For Now
4/4/2011
The Internal Revenue Service has issued a preliminary notice stating that it will not challenge a United States corporate taxpayer’s position that Puerto Rico’s temporary 4% excise tax be allowable as a credit against its federal tax liability.
Australia Reviews Consolidation Rules
4/4/2011
Uncertainty around the operation of the 'consolidation rights to future income and residual tax cost setting rules' has prompted Australian Assistant Treasurer, Bill Shorten, to commission the Board of Taxation to review the rules and clarify their scope.
Australia Issues Guidance On APAs
3/31/2011
The Australian Tax Office has released guidance for taxpayers, their advisers and ATO staff on new processes designed to enable its advance pricing arrangement program to cope with increasing demand and complexity.
AstraZeneca Settles US Tax Dispute
3/31/2011
AstraZeneca, the global biopharmaceutical company, has stated that it now expects to pay a net amount of USD1.1bn to resolve all United States transfer pricing and related valuation matters for all periods from 2000 to the end of 2010.
Transfer Pricing Remains Key Corporate Challenge
3/29/2011
The overriding observation from the 2010 Global Transfer Pricing Survey of tax directors and international tax practitioners, produced by Ernst and Young, is that transfer pricing remains a key tax challenge for the world’s leading companies.
Dunne Outlines NZ Tax Reforms
3/17/2011
Continuity and change was the theme of Peter Dunne’s speech to the International Fiscal Association Conference in Wellington last week.
Australia Aims To Attract More Foreign Regional Headquarters
2/23/2011
The Gillard Government is hoping to attract more investment by encouraging foreign-based companies to establish regional headquarters in Australia, as well as making Australian businesses with foreign operations more competitive.
Australian Transfer Pricing Ruling Welcomed
2/16/2011
The Australian Tax Office’s Taxation Ruling TR 2011/1 just released, setting out its finalized transfer pricing view on business restructuring by multinational enterprises, provides a roadmap to manage risk, according to professional services firm Deloitte.
Semeta To Propose Common EU Tax Base
2/11/2011
European Commissioner for Taxation Algirdas Šemeta has said that proposals for a common consolidated corporate tax base for firms operating in the European Union are imminent.
Report Highlights EU's Double Tax Problems
2/4/2011
The European Commission has published a new report describing responses the European Union has received from a consultation launched in mid-2010, in which respondees were asked to submit details of previous cross border tax problems.
EU Extends Mandate of Transfer Pricing Forum
1/31/2011
The European Commission has decided to extend the mandate of the European Union Joint Transfer Pricing Forum until March 2015, and has also adopted a communication setting out guidelines on two technical issues related to transfer pricing taxation.
Liechtenstein's New Tax Law In Force
1/7/2011
The government of the principality of Liechtenstein has announced the fact that since January 1 its new tax law – one of the most modern and attractive in the world – has been in force.
Italian Transfer Pricing Procedures Clarified
12/20/2010
In a circular issued on December 15, the Italian Revenue Agency has clarified the regulations for multinational companies which are able to inform the Agency that they are in possession of documents to verify the transfer pricing of their inter-company transactions.
Australia Proposes Tax Relief For Demergers
12/9/2010
Consolidated groups and multiple entry consolidated groups should find demerging and restructuring easier under proposed changes to the Australian income tax laws.
Canada To Improve Group Taxation
11/29/2010
Canada’s Minister of Finance, Jim Flaherty, has launched public consultations on the taxation of corporate groups to explore whether changes to the tax system can be made to improve its efficiency and to support economic growth.
Indian Court Delays Vodafone Tax Hearing
11/25/2010
A date of February 8 has now been fixed by the Bombay High Court for the hearing of an appeal by Vodafone International Holdings BV against a ruling by the Indian authorities that the company should pay tax on a 2007 acquisition.
Key Austrian Adviser Seeks Structural Tax Reform
11/18/2010
Despite the fact that Austria’s 2011 budget bill is still not set in stone, the country’s Labour Chamber is already pressing for a reform of taxation.
Vodafone Hits Back At Tax Protesters
11/2/2010
UK mobile phone company Vodafone has dismissed suggestions that it avoided billions of pounds in tax relating to its takeover of German telecoms company Mannesman in 2000.
Carey Olsen Advises Wolseley On Jersey Incorporation
10/13/2010
Channel Islands law firm Carey Olsen has announced that it has advised FTSE company Wolseley plc on the creation of a new group holding company, to be incorporated in Jersey with tax residence in Switzerland.
White House Under Fire Over Taxpayer Privacy
10/13/2010
Seven members of the US Senate are asking the Treasury watchdog to ascertain whether Obama administration officials illegally accessed and disclosed confidential taxpayer information.
EC Attacks Discriminatory Taxes
10/4/2010
The European Commission has sent formal requests to Germany, Greece and Belgium to change their tax rules as it considers them to be discriminatory.
Senate Kills Anti-Offshoring Bill
9/30/2010
A bill which proposed a payroll tax holiday to companies hiring American workers to replace those at a foreign-based operation whilst removing tax breaks from those companies moving operations abroad has been voted down by the Senate.
Liechtenstein Gives Green Light To Tax Reforms
9/29/2010
Determined to increase the attractiveness of Liechtenstein as a finance centre, the principality’s state parliament has adopted the government’s bill for a comprehensive reform of taxation, and has given the green light for the law to enter into force as planned on January 1, 2011.
Wolseley To Shift Tax Base To Switzerland
9/28/2010
Wolseley plc, a global distributor of heating and plumbing products and supplier of builders' products to the professional market, has announced a proposed change to the corporate structure of the Wolseley Group, which will see the creation of a new UK-listed Group holding company incorporated in Jersey with tax residence in Switzerland.
US 'Insourcing' Bill To Use Payroll Tax Breaks
9/27/2010
A bill, which will possibly be introduced in the United States Senate in the coming days, would give a payroll tax holiday to companies hiring American workers to replace those at a foreign-based operation, and remove tax breaks from those companies moving operations abroad.
UK To Forge Ahead With Corporate Tax Reform
9/22/2010
Mark Hoban, the Financial Secretary to the UK Treasury, confirmed in a speech on September 20 the government's desire to move the country towards a more territorial system of corporate taxation.
James Hardie To Appeal Australian Tax Ruling
9/20/2010
James Hardie Industries has announced that RCI Pty Ltd, its wholly-owned Australian subsidiary, will appeal to the Full Federal Court of Australia against the decision of the Federal Court rejecting the appeal of an amended assessment by the Australian Taxation Office for the income tax year ended March 31 1999.
Vodafone Loses In Mumbai High Court
9/13/2010
UK telecoms giant Vodafone has expressed continuing confidence that it is not liable for Indian capital gains tax from its purchase of the Indian mobile phone network Hutchison Essar in 2007 despite a setback in the Mumbai High Court.
ATO's Tax Claim Against James Hardie Upheld
9/8/2010
US building materials firm, James Hardie has not yet stated whether it is to appeal a recent Federal Court tax ruling, which upheld the Australian Tax Office’s claims that the firm's wholly-owned subsidiary RCI Pty Ltd owes back taxes and interest, resulting from a company restructuring in 1998-1999.
Austria's SPÖ Sets Sights On Wealth Tax
9/7/2010
During a recent meeting of Austria’s Social Democratic Party in Altmannsdorf, Austrian Chancellor Werner Faymann confirmed his party’s intention to propose additional models for taxing individuals with 'large wealth' in excess of EUR1m.
Austria's SPÖ Rejects ÖVP Wealth Tax Ultimatum
8/16/2010
Austria’s Social Democratic Party has rejected calls by coalition partner the Austrian People’s Party to relinquish any plans for a wealth tax.
Local SAT Offices Undertake Transfer Pricing Reviews
8/13/2010
China's State Administration for Taxation has directed local tax authorities to prepare statistics relating to the transfer pricing practices of companies in their tax jurisdictions as part of a wider review of transfer pricing by the central government.
Obama Signs International Tax Hikes
8/12/2010
US President Barack Obama has welcomed the approval by Congress of measures that would discourage US companies from 'shipping jobs overseas' although Republicans are warning that the bill is yet another example of the Obama administration's anti-business policies which will ultimately stifle economic growth.
US Business Fears International Tax Bill
8/11/2010
US business groups have criticized the Senate's approval of a bill which proposes to tighten international tax rules with the intention of curbing what Democrats consider as large scale corporate tax avoidance.
IRS Strengthens Focus On International Tax Compliance
8/6/2010
The US Internal Revenue Service has announced the realignment of its large and mid-size business division to create a more centralized organization dedicated to improving international tax compliance.
US To Close Foreign Tax Credit Loopholes
8/2/2010
A package of legislative proposals designed to tighten US foreign tax credit rules has been introduced in the House of Representatives as part of a bill to extend certain Recovery Act provisions.
UK Launches Raft Of Tax Consultations
7/28/2010
Exchequer Secretary to the Treasury, David Gauke, has published nine documents for discussion and consultation relating to tax, following commitments made at the June budget.
OECD Approves New Updates On Tax
7/27/2010
The Organisation for Economic Co-operation and Development Council have approved the 2010 versions of the Model Tax Convention, the 1995 Transfer Pricing Guidelines and the 2008 Report on the Attribution of Profits to Permanent Establishments.
Ireland Welcomes Covidien From Bermuda
7/22/2010
Irish Prime Minister, Brian Cowen on July 20 welcomed the opening of Covidien’s operations at the European Services Centre in Dublin. The company announced its intention in 2009 to relocate to Ireland from Bermuda.
Australia Consults On CFC Rules
7/19/2010
Australia’s Assistant Treasurer, Nick Sherry, has released for public comment a discussion paper that represents a further step towards reforming controlled foreign company rules.
White House Listens To Business Tax Concerns
7/15/2010
The Obama administration has said that its door is open to ideas from the business community on how tax and regulation can be improved to help drive forward the economic recovery.
HMRC Publishes Tax Consultations
7/6/2010
The UK tax authority, HM Revenue and Customs, has published details of the tax consultations announced by the Chancellor in the emergency budget.
Brazil Reviews Preferential Tax Regimes
7/1/2010
The Brazilian tax authority has introduced an appeals procedure in respect of its black and gray listing of preferential tax regimes, which are subject to special tax requirements.
Australia Passes Tax Reforms
6/28/2010
The Australian government has announced the passage through parliament of a number of tax reforms dealing with foreign source income, thin capitalisation rules, goods and services tax administration and managed investment trust definition, together with simplifications of corporate reporting requirements.
Investors Look Favourably On Hong Kong
6/25/2010
Hong Kong is set to benefit from the increase in investment in Asia, partly fuelled by the global financial crisis of the last two years, according to the Hong Kong government.
Switzerland Improves Group Financing Conditions
6/24/2010
In a bid to improve the Swiss financial centre and to create jobs in Switzerland in the area of internal group financing activities, interest paid out between companies of the same group will in future be exempt from withholding tax and stamp duty.
Hong Kong Signs DTAs With UK, Ireland
6/24/2010
Hong Kong has signed comprehensive agreements for the avoidance of double taxation with the United Kingdom and Ireland, on June 21 in London and June 22 in Dublin, respectively.
Italy Introduces Transfer Pricing Guidelines
6/9/2010
The Italian government has issued law decree 78, which contains a section bringing Italian transfer pricing documentation rules in line with Organization for Economic Cooperation and Development transfer pricing guidelines.
Vodafone Appeals Indian Tax Order
6/9/2010
UK telecoms multinational Vodafone has responded to the Indian Income Tax department's reassertion of its jurisdiction to levy withholding tax on the USD11.1bn sale to Vodafone of a 67% stake in Hutchinson Essar in 2007 with an appeal to the Bombay High Court.
Spanish Dividend Tax 'Discriminatory'
6/8/2010
The European Court of Justice has upheld the European Commission's contention that Spain's treatment of domestic and foreign shareholders under its participation exemption regime contravenes article 56 of the EC Treaty on the free movement of capital.
India Asserts Tax Claim Against Vodafone
6/7/2010
The Indian tax authorities have reasserted their belief that they have jurisdiction to levy withholding tax on the USD11.1bn sale to Vodafone of a 67% stake in Hutchinson Essar in 2007.
Ireland Set For New Transfer Pricing Rules
6/7/2010
Speaking at PricewaterhouseCoopers’s ‘Supporting Growth - Protecting Wealth’ conference, Siobhan Baldwin, Tax Director in PwC’s Private Company Services arm, warned of changes to Irish transfer pricing rules that will affect arrangements made after July 1, 2010.
Thailand To Cut Tax For Regional HQs
5/31/2010
Thailand’s Deputy Finance Minister, Pradit Phataraprasit, has disclosed that the government plans, from June 1 this year, to provide substantial tax incentives for domestic and foreign companies establishing regional headquarters in the country.
OECD Releases Tax Convention Update
5/24/2010
The Organization for Economic Cooperation and Development Committee on Fiscal Affairs has released the draft contents of the 2010 update to the Model Tax Convention.
Vietnam Provides Transfer Pricing Guidance
5/21/2010
Vietnam has published details of changes in filing and documentation in a new tax circular, which amends its transfer pricing regulations.
US, India Reach Transfer Pricing Agreement
5/21/2010
The US and Indian tax authorities have negotiated a settlement on a transfer pricing dispute concerning taxable profits of captive IT services and research subsidiaries of US companies.
China And HK Examine Transfer Pricing
5/19/2010
The Chinese State Administration of Taxation and the Hong Kong Inland Revenue Department have held a joint public seminar in Hong Kong, under the auspices of the Hong Kong Taxation Institute, to discuss the latest developments.
Liechtenstein Adopts Tax Reform Law
5/7/2010
Liechtenstein’s government has approved plans for creating a new tax act, designed to modernize the existing Liechtenstein Tax Act of 1961.
Austria Plans EUR4.1bn In Tax Rises
4/21/2010
According to a recent strategy report for 2011-2014, Austria’s coalition government aims to generate an additional EUR4.1bn in tax revenue by 2014.

 

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