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  • Henry An David Jin-Young Lee The Ministry of Strategy and Finance has proposed a series of measures to help facilitate economic recovery. The proposed changes will become effective following approval by the National Assembly in its temporary session to be held in April 2009.
  • Marius Ionescu Lucian Barbu Transfer pricing is set to become an increasingly important topic for the Romanian tax authorities and taxpayers.
  • Peter Dachs Recent media statements by national Treasury have focussed attention on anti tax-avoidance issues. The first media statement was issued in March 2008 and described a transaction where an operating company (seller) sells its business to a Newco on a tax free basis. Newco funds itself with external debt to acquire the business.
  • Sponsored by Garrigues Portugal
    Portugal has historically favoured source-based taxation on passive income, which has been coupled with stringent documentation requirements to claim the application of tax treaties (the so-called RFI forms). The Portuguese tax authorities have recently published a new set of procedural forms, this time to apply the transitional regime under the interest and royalties directive (council directive 2003/49/EC). Those developments provide a good pretext to outline the current state of play concerning outbound interest and royalty payments.
  • Finn Eide Every year for the past 25 years, there has been at least one court case questioning a permanent establishment (PE) on the Norwegian Continental Shelf (NCS). In the majority of cases, the question is not whether or not there is a PE - but allocation of income and cost to the PE.
  • Janina Fornalik On December 22 2008 the European Court of Justice (ECJ) handed down a ruling (case file C-414/07) stating that Polish VAT provisions placing restrictions on the deduction of VAT on the purchase of fuel to vehicles are contrary to the European Community regulations. The ruling was issued with regard to the dispute pending before the Polish regional administrative court in Cracow between the Polish tax authority (director of the tax chamber in Cracow) and Magoora. The Polish court decided to refer the questions to ECJ for a preliminary ruling with respect to the conformity of national law with the EU regulations.
  • The corporate tax system that created Ireland's economic success story is still in place. It has other benefits apart from the headline rate, argues Kevin McLoughlin of Ernst & Young
  • By Joanna Faith
  • Uncertainty about the fate of the global economy and a more uncompromising attitude generally from tax authorities around the world has encouraged taxpayers to go to tax planning with long-standing reputations. As a result, the biggest professional services firms are near or at the top of International Tax Review's second annual poll to find the world's leading planning practices
  • Prasad Paranjape of PricewaterhouseCoopers says that careful planning can overcome the intricacies of service tax
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