Indian Budget Retains Corporate Tax Rate, Fails to Add Bilateral Arrangement for APAs

India’s 2010 budget proposal, introduced to Parliament Aug. 30, aims to eliminate some secondary corporate tax fees, while also retaining wording from last year’s budget on initiating a unilateral advance pricing agreement program — disappointing practitioners who had sought a bilateral option in the program when it begins in 2011. The Direct Taxes Code Bill [...]

Russian Finance Ministry Issues Guidance Allowing Use of IRS Form for S Corporations

MOSCOW — The Russian Finance Ministry issued guidance Aug. 24 that allows certain S corporations to use Internal Revenue Service Form 6166 as a residency certificate for corporate profit tax purposes. In Letter No. 03-08-05, the ministry commented on whether the IRS form, issued to S corporations receiving copyright and license revenue in Russia, may [...]

Belgium: ECJ decision in the Dijkman case (C-233/09) on supplementary municipal tax on foreign sourced movable income

Olivier Hermand, Patrice Delacroix, PricewaterhouseCoopers TLS Corporate Tax Brussels Belgian individual taxpayers are normally due to declare their taxable income, including movable income (interest, dividends, etc.) in an annual income tax return filed with the Belgian tax authorities. According to Article 313 of the Belgian income tax code (“BITC”) however, the said taxpayers are not [...]

British Columbia Court Upholds Petition To Seek Withdrawal of Harmonized Tax

OTTAWA — The Supreme Court of British Columbia upheld Aug. 20 the validity of a petition signed by more than 700,000 of the province’s taxpayers that demands that the provincial legislature reconsider its controversial decision to implement a harmonized sales tax (John Allan et al. v. The Chief Electoral Officer, Supreme Court of British Columbia, [...]

Astra Zeneca and VAT: When sacrifices can be painful

Richard Woolich, Tax Partner, DLA Piper UK LLP, London On July 29, the European Court of Justice (ECJ) delivered its judgment in Astra Zeneca UK Limited v. HMRC (Case C-40/09). The reference to the ECJ was for a preliminary ruling on the VAT implications of an employer issuing to its employees vouchers with a cash [...]

The Developing Aftermath of the UBS Affair: A New Tax Order

Joseph M. Erwin, Attorney at law, Dallas The UBS Affair — a case of tax evasion by collusion between U.S. citizens and foreign financial institutions—is not a new phenomenon. It is, however, probably the broadest in scope, based on the numbers of recalcitrant taxpayers and the size of the financial institution involved. It is a [...]

China: Sino-foreign joint ventures

Dr Ulrike Glück, CMS China, Shanghai Joint Ventures are still a popular investment vehicle for many foreign investors who do business in China. Sino-foreign joint ventures can take the form of equity joint ventures or co-operative joint ventures. As to the qualification requirements for Chinese joint venture partners, the current Chinese laws at national level [...]

United Kingdom: Consultation on taxation of foreign branches and interim improvements to CFC Regime announced

Ingrid Gardner (New York), Gregor Lindsay (New York), Gareth Hughes (New York), Abigail Martin (New York) and Peter Cussons (United Kingdom), PricewaterhouseCoopers, United States and United Kingdom On July 27, 2010 HM Treasury (“HMT”) released an update on proposals to reform foreign branch taxation, as well as additional information on the proposals to improve the [...]

EU Member States Aim to Slow Growth of Budget

European Union national governments Aug. 12 slashed almost four billion euros from a proposed EU budget, opening up heated discussions on the EU’s role and the funding it needs. The EU’s executive body were asking for a 5.7 percent increase in the budget, but the 27 member states who foot the bill are proposing a [...]

Challenging Customs in the United States Court of International Trade

Lawrence M. Friedman  ,Partner, Barnes, Richardson & Colburn, Chicago The United States Court of International Trade is the sole forum in the United States in which an importer can challenge many final decisions of the United States Bureau of Customs and Border Protection. These administrative decisions range in nature from the admissibility of merchandise to [...]

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