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  • The European Commission has formally requested that Germany amends its anti-abuse provisions on withholding tax relief. While not criticising the aim of the anti-abuse measure, the Commission is concerned about the disproportionality of one provision under which companies have to prove the existence of genuine economic activity of their foreign subsidiaries to obtain the relief.
  • The Delhi High Court has ruled that the obligation to withhold tax would arise only if the income is liable to tax in India.
  • Hong Kong's Inland Revenue Department (IRD) has clarified the residency rules for offshore funds, just over a month after the financial secretary reiterated the importance of promoting asset management business in the territory.
  • The German government plans to introduce R&D tax incentives to attract and sustain investment in the country and also to comply with an EU-wide R&D initiative.
  • Namibia is set to cut the corporate tax rate for non-mining companies as well as make important changes to withholding tax rules on interest.
  • Tarsem Basran is leaving the London office of TMF VAT & IPT Services to join its New York global insurance premium tax compliance team.
  • Passarella Abogados is a new firm in Buenos Aires that has been set up by Leandro Passarella, a well-known tax lawyer. He advises corporations on the Argentine tax implications of M&A transactions, reorganisations and leveraged buy-outs, and the tax-efficient structuring of businesses and start-ups in general. He also designs tax structures for regional transactions and operations. His practice includes the legal assistance to clients in tax audits and litigation.
  • Sergio Crespo has joined Cuatrecasas, Gonçalves Pereira as a partner in its Barcelona office.
  • Fred Adam has joined KPMG's Silicon Valley office as an international corporate services principal.
  • The Ninth Circuit Court of Appeals has overruled a lower court decision and found that a bank may recover excess taxes it paid after purchasing distressed savings and loan (S&L) associations.
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