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International Tax Services (ITS) - Archives
2010
November 2010
- The Netherlands – 2011 Dutch Tax Package announced
- UK - Proposal to UK Finance Bill 2011
- Ireland - Irish Government Re-affirms Commitment to the 12.5% Corporate Tax Rate.
- The Netherlands – Court of Appeal of Amsterdam posed three preliminary questions to the European Court of Justice about the application of a Dutch exit tax levied upon the emigration of a Dutch BV
- Switzerland - Amendments of Withholding Tax and Stamp Duty Directives Related to Intercompany Financing
- Ireland - Irish Withholding Tax Regime on Royalties Simplified
- India - New Proposed Direct Taxes Code, 2010
- China - "The Administrative Measures of CIT Treatments for Corporate Restructuring" issued by China's State Administration of Taxation
- Brazil – Introduction of Thin Capitalisation Rules
- South Africa - Draft Amendment Bills for 2010
5 August 2010
- UK – A budget, by George
- Greece – Significant tax reform in Greece
- Malta – Amendments to Maltese tax law affecting international business
- Brazil – New list of ‘tax havens’ and ‘privileged tax regimes”
- Ireland – Irish tax authorities issue guidance on transfer pricing documentation
- Denmark - First Danish case on beneficial ownership
- Sweden – Proposed amendments of Swedish CFC rules
02 June 2010
- Luxembourg– State of the nation: New tax measures
- France - French Administrative Supreme Court releases positive decision to commissionaire structures
- Spain - Spanish National Court confirms that taxes paid in breach of EU law must be refunded
- Bulgaria – Transfer pricing documentation
- Ukraine – Participation exemption enhanced
- Australia - The tax reform agenda
- Indonesia - New Developments in applying Tax Treaties – Relaxation and Clarification of Rules
- Taiwan - Tax updates
- Republic of Congo – Change of interpretation in Congolese Tax Law
14 April 2010
- European Commission – Belgium, Denmark and the Netherlands are requested to change exit tax provisions for companies; case is closed against Sweden
- France – France issues transfer pricing documentation requirement regulations
- Japan – Japanese Tax Reform legislation 2010
- China – Clarification of tax treatment of royalty and technology transfer related service fees
- China – Significant changes in taxation rules for Representative Offices of foreign enterprises in China
3 March 2010
- US – Tax Reform: Obama Administration FY 2011 budget proposal
- Ireland – Finance Bill 2010 published (introducing transfer pricing rules)
- Spain – 2010 Finance Law - Taxation measures of relevance to inward investors
- The Netherlands – ECJ: Dutch fiscal unity regime not in breach of EU Law
- Korea – Tax law changes for 2010
- Korea – Introduction of the Consolidated Tax Return regime from fiscal year 2010
- Norway – Government proposal on tax treatment of reorganisations
26 January 2010
- Belgium - Belgian Tax Law Changes 2010
- France - France Amended Finance Act for 2009
- Germany - Economic Growth Acceleration Bill including important tax law changes passed
- China - New Form of Investment for Foreign Investors – Foreign-invested Partnership
- China - Overseas Indirect Equity Transfer by Non-China Tax Residents under Scrutiny
- Hong Kong - The revised DIPN 21 on locality of profits - Adding clarity?
- Brazil - Brazil introduces thin capitalisation rules
- Cyprus - Amendments to the Income Tax and Special Contribution for the Defence of the Republic Law
2009
17 December 2009
- Belgium – European Court of Justice Cobelfret case further implemented in supplementary Administrative Circular
- The Netherlands - Update State Secretary of Finance on limitation of interest deduction and interest box regime
- France – New legislation to tackle tax evasionThe French Government has just issued draft legislation strengthening existing tax law regarding companies who operate with Non-Cooperative States or Territories.
- Germany – German Draft Bill Provides Limited Tax Relief
- UK – High Court judges Thin Cap GLO
- USA – Codification of the economic substance doctrine could have broad impact on corporate transactions
- China – China provides guidance on "beneficial ownership" requirements for claiming tax treaty benefits for passive income
- Russia – New Russian transfer pricing draft law is available
- Lithuania - Proposed Tax Changes in Lithuania
- Australia – ATO Seeks to tax foreign investors on disposal of Australian investment
16 November 2009
- China – Belgium – New Double Tax Treaty between Belgium and China (People’s Rep.)
- European Commission – The EC recommends simplified procedures for claiming back crossborder withholding tax relief
- Germany – German cabinet resolves draft Economic Growth Acceleration Bill including important tax law changes
- Spain - The European Commission qualifies the Spanish goodwill amortisation scheme as State Aid
- Sweden - Implementation of an advance pricing agreement (APA) programme as from 1 January 2010
- Poland – Poland -US tax treaty update
- Hungary – Change of corporate income tax rate
19 October 2009
- Belgium - New guidelines on functional currency for intra-group treasury and finance companies
- The Netherlands – 2010 Tax Package announced on 2009 Budget Day
- Preview – U.S. Tax Reform proposal: Is it relevant for you?
- China - Treaty Residents Having Clearer Rules for Claiming Benefits under Double Tax Treaties
- China – Clearer Rules for Royalties under Double Tax Treaties
- European Commission – Marks & Spencer case: UK referred to the European Court of Justice
- France – Business Tax Reform
- Hungary - A summary of the most important amendments affecting corporate income tax
17 September 2009
- France - French Finance draft Bill to include tax anti-abuse measures
- China - Permanent Establishment Risk on Secondment Arrangement
- Italy - Scope of Controlled Foreign Corporations (CFC) rules broadened
- Greece - Thin capitalisation and transfer pricing rules
- UK - Budget for 2009-10: Finance Act 2009 receives Royal Assent: summary
19 August 2009
- Belgium/UK - 2009 Protocol to the 1987 Belgian-UK Tax Treaty includes Zero Withholding Tax on Interest
- The Netherlands – European Commission: ‘groepsrentebox’ is not state aid
- Spain - Spanish tax provisions related to the capital duty and the exchange of shares incompatible with the European Union Law.
- Denmark - Bill passed on Harmonisation of the Taxation of Dividend and Capital Gains
- India – The Indian Union Budget
- Luxembourg has been removed from the OECD 'grey-list'
22 June 2009
- Belgium – ECJ: Expected extension of Cobelfret case law (C-138/07) to internal situations, and potentially to third countries.
- The Netherlands - CIT 2010
- UK - Doing Business and Investing in the UK
- Mexico - Presidential Decree addressing tax incentives may benefit taxpayers and certain industries.
- United States - US Tax Treaty Developments
- New PwC Publication: The 2007 Belgium-US Double Tax Treaty - An effective gateway for doing business
25 May 2009
- The Netherlands: Meeting the challenges of the current financial crisis - a Dutch tax perspective - Part II
- The Netherlands: Extended possibility to claim a preliminary carry back of 2008 losses
- Ireland's April 2009 Budget reaffirms 12.5% corporation tax rate and announces significant enhancement of intellectual property regime
- Luxembourg Government's measures for economic recovery
- Germany: Update on prospective tax law changes
- UK Budget 2009
- United States: Focusing on the impact of emerging developments
- France: Being in the starting blocks for the tax measures of the French reflation plan
- Japan: Japanese Diet Passes 2009 Tax Reform Legislation
3 April 2009
- Singapore: Budget Commentary 2009 – Braving the storm
- United States: US Inbound Newsalert
- Sweden: Swedish group relief system is not in line with the freedom of establishment, says Swedish Supreme Administrative Court
- China: China issues new tax circular regarding the administration of withholding income tax on passive income
- Czech Republic: Proposed amendment to income tax act
- Switzerland
5 March 2009
- Denmark – Corporate tax reform
- Belgian participation exemption regime not in line with the parent-subsidiary Directive (Cobelfret Case; C-138/07)
- Indonesia: Income tax bill is passed into law
5 February 2009
- The Netherlands: Meeting the challenges of the current financial Crisis- a Dutch tax perspective
- Protocol to US-France income tax treaty signed
- US Tax policy in transition - 2009 Tax legislative outlook
- Czech Republic: Amendment to Income Tax Act
- Cyprus: List of financial instruments that are considered as qualifying "titles"
- Luxembourg: Corporate Tax Reform 2009
- Spain: Important amendments to the Spanish tax legislation in effect since 1 January 2009
- Switzerland to make important Corporate Tax Reform in order to improve competitiveness
- China: Unveiling of long-awaited special tax adjustments implementation measures
- Israel: Draft legislation on taxation of foreign residents and on repatriations
5 January 2009
- Irish Budget 2009 - Key tax proposals
- Ireland’s 2009 Budget hints at favourable intellectual property changes and reaffirms 12.5% tax rate
- Ireland: Finance Bill amendments include new tax incentive for expatriate assignees and additional positive tax developments
- Update on German Tax Act 2009
- Portugal: Budget Act Proposal 2009
- Ukraine: Maximum interest rate restrictions on loans from non-residents changed
- Latvia: New corporate income tax measures
- Estonian tax changes, effective as of 2009
- Australian Taxation Office discussion paper issued could impact on interest deductibility.
- China announces new thin capitalisation ratios
2008
22 October 2008
- Greece 2008 Draft Tax Bill
- Abolition of capital duty in Luxembourg: Another step forward!
- Luxembourg – Draft 2009 budget and new tax measures.
- Estonia- Corporate Tax Reform 2009 partly postponed
- The Norwegian fiscal budget 2009 - the key tax proposals
- Denmark: Bill released to strengthen Danish anti check-the-box rules in connection with “un-checking” of Danish companies.
9 July 2008
- Advocate General’s Opinion in Cartesio case (C-210/06)
- The Swedish Tax Agency suggests new rules as from January 1, 2009
- Luxembourg Government Announces Abolishment of Capital Duty and Corporate Income Tax reduction in 2009
- Estonian Corporate Tax Reform 2009
16 May 2008
- European Court of Justice case C-138/07 (Cobelfret)
21 April 2008
- 2nd protocol to the China/Hong-Kong Tax Treaty
- IFA Belgium represents the interests of Belgium through delegates on the different bodies of the International Fiscal Association (IFA International).
- United Kingdom: Budget 2008
- Circular letter 03/04 Notional Interest Deduction
20 March 2008
- The recent changes to the Hungarian tax legislation
- Additional information on the new U.S.-Belgium Double Tax Treaty
- Ireland - 2008 Finance Bill
Contacts
- Frank Dierckx
- Managing Partner Tax
- Tel: +32 (2) 710 4324
- Axel Smits
- Partner & ITS Leader
- Tel: +32 (0)3 259 3120
- Philippe de Clippele
- Director
- Tel: +32 (0)9 268 8310
Of further interest
- Tax Freedom Day
- PwC worldwide tax summaries
- Doing Business guide in Belgium
- Study: Paying Taxes 2010 – the global picture
