News stories prepared by PricewaterhouseCoopers' global tax group for Europe, Latin American, and the Asia-Pacific theaters.
International newsalerts – Foreign
PricewaterhouseCoopers provides international tax services to companies operating cross border. The international tax services network provides access to recent tax news and advice on holding company structures, cross border financing and treasury solutions, controlled foreign company planning, profit repatriation, loss utilization, inbound and outbound structuring, managing intellectual property, tax efficient supply chain and shared services, and Asian, European and Latin American tax law.
The international tax services newsalerts provide tax news, tax technical developments and planning ideas related to specific country issues.
Australia
Tax rules for scrip mergers announced (36kb) – October 19, 2007
Australian taxation of financial arrangements: Draft legislation introduced (49kb) – October 18, 2007
Tax preferred entities asset financing in Australia (34kb) – October 8, 2007
New foreign tax credit and foreign loss rules (38kb) – June 29, 2007
Updated exposure draft legislation on the taxation of financial arrangements in Australia (34kb) – February 20, 2007
Australia repeals capital gains tax on dispositions by non-residents of shares in Australia companies without substantial Australian real estate holdings (37kb) – December 12, 2006
Belgium
The US ratification process nears completion on tax agreements with Belgium, Denmark, Finland, and Germany. (28kb) – July 25, 2007
Bill of law: 80% tax deduction for patent income (36kb) – March 20, 2007
VAT grouping in Belgium (86kb) – December 13, 2006
New US-Belgium double tax treaty includes a zero withholding tax on dividends and interest (44kb) – December 4, 2006
Abolishment of withholding tax for dividend payments to treaty countries (33kb) – October 25, 2006
Brazil
Brazil tax update (34kb) – April 19, 2007
Brazil/Mexico tax treaty now in force (32kb) – January 10, 2007
Withholding tax rate reduction under Brazil-Spain tax treaty (61kb) – April 10, 2006
New rules provide tax rate reductions for foreign investors in connection with certain types of investments (62kb) – February 22, 2006
New temporary transfer pricing rules (58kb) – February 1, 2006
China
China's new corporate tax law: Update on the draft detailed implementation rules (34kb) October 9, 2007
New Chinese withholding tax on dividends considered likely beginning in 2008 (24kb) September 18, 2007
New double tax treaty between China and Singapore (38kb) July 31, 2007
Significant changes on Chinese export VAT refund rates (34kb) June 22, 2007
Interpretation and implementation notice for double tax arrangement between mainland China and Hong Kong (29kb) April 25, 2007
Fundamental change in Chinese income tax law may require immediate consideration (31kb)
April 2, 2007
Impact of the new China corporate income tax law on foreign investors (36kb)
March 22, 2007
Latest update on the legislation process for the unified corporate income tax law (36kb)
March 12, 2007
Update on the new unified corporate income tax law in China (37kb) – January 22, 2007
First bilateral advanced pricing agreement ("APA") between China and the US (21kb) – January 15, 2007
China issues new circular on M&A rules for foreign investors in domestic enterprises (45kb) – August 30, 2006
Hong Kong-China sign double taxation agreement (116kb) – August 23, 2006
China cancels business tax exemption for interest and rental income derived by foreign companies (1.02mb) – June 16, 2006
China adopts new consumption tax policy (64kb) – April 3, 2006
China curtails establishment and renewal of Chinese liaison offices by foreign investors (66kb) – February 21, 2006
The PRC State Administration of Taxation streamlines the administration of the advance pricing arrangements (30kb)
January 9, 2006
Colombia
Colombian tax update (55kb) – April 3, 2007
Denmark
The US ratification process nears completion on tax agreements with Belgium, Denmark, Finland, and Germany. (28kb) – July 25, 2007
New Danish tax proposal (36kb) – February 7, 2007
European Union
CFC Intra - EU precluded if extending beyond "wholly artificial arrangements" (50kb) – September 12, 2006
Finland
The US ratification process nears completion on tax agreements with Belgium, Denmark, Finland, and Germany. (28kb) – July 25, 2007
France
Withholding tax exemption on dividend payments from France to EU shareholders (36kb) – June 12, 2007
Germany
German corporate tax reform 2008: The impact on accounting for income taxes (113kb) – October 1, 2007
The US ratification process nears completion on tax agreements with Belgium, Denmark, Finland, and Germany. (28kb) – July 25, 2007
Multi-tier holding structures and the German treaty shopping rule (37kb) – July 18, 2007
2008 tax reform passed (37kb) – July 6, 2007
Anti-treaty shopping rule may adversely affect holding company structures of US multinationals (35kb) – March 28, 2007
2008 tax reform update (35kb) – February 13, 2007
2008 tax reform (26kb) – February 2, 2007
Corporation tax refund claim (29kb) – December 18, 2006
2007 German tax bills (39kb) – November 28, 2006
German court rules that 5% disallowance of deemed expenses violates EU law (26kb) – November 14, 2006
2008 tax reform proposal (30kb) – November 3, 2006
German circular published on advance pricing agreements ("APAs") (35kb) – October 19, 2006
German circular published on German anti-debt push down rule (32kb) – October 3, 2006
US-German tax treaty: Ratification process in the US on hold (33kb) – August 25, 2006
German treaty override provisions proposed to be changed (1.06mb) – July 17, 2006
New protocol to US-German tax treaty drafted (1.13mb) – May 26, 2006
India
Indian budget 2007: Tax proposals (26kb) – March 15, 2007
Ireland
Revised treatment of inbound employee secondments to Ireland may reduce VAT costs on recharges; also, patent royalty exemption changes are included in the finance bill 2007 amendments (34kb)
March 8, 2007
Ireland implements european company (SE) provisions and introduces tax changes in finance bill 2007 (37kb)
February 5, 2007
Ireland’s finance bill 2006 abolishes capital duty and restricts interest relief on related-party borrowing (55kb)
February 3, 2006
Italy
Proposed 2008 finance bill (22kb) – October 5, 2007
Japan
Tax reform proposals 2007 (30kb) – March 15, 2007
Korea
Proposed introduction of partnership taxation in Korea (33kb) – August 30, 2007
New withholding tax rule for foreign companies domiciled in tax haven jurisdictions: Labuan designated as a tax haven jurisdiction (41kb) – July 7, 2006
Luxembourg
End of the Holding 1929 Tax Regime: December 2010 (48kb) – July 21, 2006
Malta
Draft legislation to amend income tax act published in Malta (32kb) – January 10, 2007
Mexico
Mexican executive branch decree addressing flat tax (35kb) – November 12, 2007
Mexican flat tax and tax on cash deposit are approved by the Mexican Congress (38kb) – September 18, 2007
Proposed Mexican alternative minimum tax may have significant impact on many traditional Maquiladoras (28kb) – June 29, 2007
Mexican executive branch submits 2008 tax reform bill to Congress for analysis and approval (32kb)
June 21, 2007
New Canada-Mexico tax treaty published in the Official Gazette (26kb) – April 13, 2007
2007 Mexican tax, penalty, interest and abatement (amnesty) procedures clarified (31kb) – April 3, 2007
Extended due date for Mexican transfer pricing tax return annex (27kb) – March 30, 2007
New rule to clarify permanent establishment limitations on Mexican Maquiladora operations (32kb) – March 29, 2007
Determining uncertain tax positions under FIN 48 for operations in Mexico (43kb) – February 26, 2007
Brazil/Mexico tax treaty now in force (32kb) – January 10, 2007
Mexico – 2007 Mexican tax reform bill approved by Congress (40kb) – December 22, 2006
Mexican income tax regulations regarding PE limitations on Maquiladoras (43kb) – December 20, 2006
Significant proposed amendments to Mexican tax law (32kb) – December 14, 2006
New decree for the promotion and operation of manufacturers, Maquiladoras and export services companies (IMMEX) (50kb) – November 7, 2006
Mexican federal tax code reforms (65kb) – July 14, 2006
New Mexican transparent venture capital investment trusts (61kb) – January 18, 2006
Mexico: Extension of Exhibit 24.2 (Deferred Consolidated Income Tax and Asset Tax) (69kb) – January 12, 2006
The Netherlands
Tax changes for the calendar year 2007 (29kb) – February 12, 2007
Important tax changes in the Netherlands for the Year 2007 (26kb) – November 28, 2006
Tax cut proposals in the Netherlands for the year 2007 (98kb) – May 25, 2006
Tax cut proposals in the Netherlands for the year 2007 (96kb) – April 25, 2006
Netherlands: Changes in Dutch tax law per 2006 (1.02mb) – January 6, 2006
Norway
2008 fiscal budget proposed in Norway (31kb) – October 15, 2007
Portugal
Proposed 2008 budget act in Portugal (27kb) – October 17, 2007
The ECJ rules against the Azores (Portugal) regional tax benefits (24kb) – October 23, 2006
Spain
Amendment of Spanish-Swiss tax treaty to enter into force on June 1, 2007 (35kb)
March 27, 2007
Spain-Malta double tax treaty ratified (23kb) – October 19, 2006
US and Spain reach competent authority agreement on LLC treatment (84kb) – March 21, 2006
Anti-abuse measures and new transfer pricing rules announced (69kb) – February 16, 2006
Sweden
Swedish transfer pricing documentation requirements (32kb) – December 14, 2006
Switzerland
Amendment of Spanish-Swiss tax treaty to enter into force on June 1, 2007 (35kb)
March 27, 2007
Thailand
US-Thailand Treaty of Amity and Economic Relations Extended until December 5, 2006 (33kb) – October 2, 2006
New Thai tax incentives to promote securitization projects, Thai holding companies, energy savings and employee skills development (46kb) – January 4, 2006
United Kingdom
Pre-budget report 2007 (33kb) – October 12, 2007
UK publishes consultation document on taxation of foreign profits (28kb) – June 21, 2007
UK Budget 2007 delivered by Chancellor on March 21, 2007 (82kb) – March 22, 2007
European Court of Justice judgement regarding pre-2004 UK thin capitalization rules (36kb)
March 19, 2007
UK Court of Appeal Judgment Concerning European Union Cross-border Loss Relief (36kb)
March 5, 2007
UK taxation of foreign dividends (36kb) – December 13, 2006
Pre-budget report 2006 (35kb) – December 8, 2006
The new UK-Japan double taxation treaty entered into force on October 12, 2006 (33kb) – October 17, 2006
UK tax authorities announce group relief changes in finance bill 2006 following the Marks & Spencer ECJ judgement (56kb) – February 24, 2006
Uruguay
Uruguayan tax update (38kb) – April 13, 2007
Uruguayan government drafts major tax reform bill (76kb) – February 22, 2006
Venezuela
Venezuela withdraws from the Andean community and G-3 to join Mercosur (60kb) – June 13, 2006
