Search results for

Takeo Mizutani Michael Shikuma A temporary measure to expand the exemption from Japanese withholding tax to include certain onshore issuances of corporate bonds (the exemption) came into effect last month. The exemption is effective for interest accruing from June 1 2010 on any qualifying bond issued before April 1 2013, including bonds that have already been issued (bonds issued before April 1 2010). Thus, interest accruing after March 31 2013 will still continue to qualify if the bond was issued before April 1 2013.

Rajendra Nayak Ganesh Pai The Mumbai Income Tax Appellate Tribunal in the case of Valentine Maritime Mauritius [2010-TIOL-195-ITAT-MUM] ruled on the taxability of certain contracts executed in India under the India-Mauritius tax treaty. The taxpayer is a company incorporated in Mauritius and is engaged in the business of marine and general engineering and construction. During the relevant tax year, the taxpayer executed three contracts in India: (1) Replacement of a deck; (2) Charter of a barge (for accommodation purposes); (3) Charter of a barge along with the provision of technical personnel. Under the treaty, a permanent establishment (PE) includes a building site or construction or assembly project or supervisory activities in connection therewith where such site, project or supervisory activities continue for a period of more than nine months (construction PE rule). While each of the contracts taken individually lasted for a period of less than nine months, the aggregate time spent on all the contracts put together exceeded the nine months time threshold. The main issue before the tribunal was whether the taxpayer has a PE under the construction PE rule of the treaty.

Elena Kostovska The small and open economy of FYR Macedonia continues to take steps towards attracting foreign direct investment with legislative changes that equalise conditions for foreign and domestic investors as well as with extensive investment incentives.

Stephen Dale Arnaud Moraine The French real estate VAT regime changed fundamentally from March 11 2010. The objectives of the French government in amending the VAT regime, applicable to Real Estate, are:

The most admired tax directors in Europe, from a poll of International Tax Review's readers, reveal what has changed about their roles since the beginning of widespread recession. Cooperation with their business colleagues has become closer and they still value the external advisers that get to know their business properly

A booming economy and an increasing focus on investment is forcing the Indian tax authorities to step up scrutiny on all cross border trade. Rohan Phatarphekar and Hardev Singh of KPMG outline how transfer pricing will be the hot topic over the coming year.

David Spencer analyses the Foreign Account Tax Compliance Act in the US and discusses the effect it may have on the attitude of other countries to the automatic exchange of tax information

Recent rulings are likely to suggest anti-avoidance regulations are on the way to India, explain Ajay Kumar and Amit Agarwal of PricewaterhouseCoopers.

Rahul Mitra and Nishant Saini, of PricewaterhouseCoopers, discover how the concept of permanent establishment in India is not as straight forward and subject to much debate.

A complete re-write of the country's 1961 income tax law, a goods and service tax, a new advance pricing agreement programme, a growing litigation problem and a heightening risk of audits means the next year in India will be one of the busiest ever. Jack Grocott investigates.