Search results for

Due to the closure of European airspace, this event will now be will held on June 16.

The tax authorities in the UK are looking at the effectiveness of ADR to resolve tax disputes. Lessons can be learnt from other jurisdictions who have previously implemented schemes, says Richard Doran of Dorsey & Whitney

Maricla Pennesi of DLA Piper analyses why the Italian tax authorities have become more aggressive recently in the fight against international tax evasion

Gerry Thornton In a step aimed at promoting Ireland as a centre for Islamic finance, Ireland has recently confirmed the Irish tax treatment of Shari'a-compliant financial products. Ireland is already a leading financial services jurisdiction and this certainty of tax treatment for Shari'a-compliant products should further enhance Ireland's international reputation as one of the most attractive jurisdictions for alternative financing arrangements. This article summarises the main tax points from the perspective of international arrangers and investors.

Loreto Pelegrí H Rodrigo Winter S Chilean Income Tax Law provides that interest payments by a Chilean resident to a foreign person are subject to a 35% withholding tax. The rate is reduced to 4% in the case of interest arising from loans granted by foreign or international banks or financial institutions, or interest arising from amounts outstanding that result from the import of goods under the deferred coverage system and from bonds or debentures in foreign or local currency.

Lorena Kurti The strong relations between Albania and Germany are evident throughout the years and especially since 1991. Considering Germany's support by way of development aid to the country, the presence of a number of German companies in Albania and the need for further development cooperation, it was only a matter of time before a double tax treaty between the two countries was concluded.

Ian Farmer On May 2 2010, the Australian Government released the Henry Review into Australia's tax and transfer system, which it commissioned almost two years ago. More importantly it also released its response to the Henry Review which it was hoped would set out a blueprint for tax reform for the foreseeable future in Australia.

Janne Juusela On March 12 2010 the Finnish Supreme Administrative Court issued two rulings concerning taxation of cross-border dividends. Based on the rulings both Finnish investors and foreign investment funds may be entitled to tax refunds.

Janette Pantry Rebecca Levi The Canadian federal government is proposing to require mandatory disclosure of certain tax avoidance transactions.

Jobst Wilmanns Dirk Wilcke In 2008, Germany introduced two new concepts into its transfer pricing regime, the transfer of functions and the hypothetical price comparison. Both are interlinked. The function transferred to a foreign related party is to be valued as a whole, rather than as the sum of the individual asset values. The hypothetical price comparison is the most appropriate point within the range between the lowest price at which a seller would still be willing to sell and the highest price a buyer would still be prepared to pay. Both values assume full knowledge of the circumstances on the part of everyone involved, but both are nonetheless subjective, if only because an actual buyer cannot, in the nature of things, be consulted. Not surprisingly the new concepts were met with scathing criticism.