Customs Union of Russia, Belarus and Kazakhstan

Igor Ostapets, Irina Dmitrieva, Igor Kornev and Artem Toropov, White & Case LLC, Moscow I. Introduction Russia, Belarus and Kazakhstan form the Customs Union within the framework of the Eurasian Economic Community (“EurAsEC”), an international economic organization aiming to shape common external customs borders of its member countries and to develop a common external economic [...]

Dutch Budget: Tax proposals 2011 reduce tax burden in the Netherlands in 2011

Maarten de Bruin, Michael Molenaars, Emil Bongers, Jean-Paul van den Berg and Johan Vrolijk, Stibbe, Amsterdam, London and New York Despite the fact that the Netherlands currently has an outgoing government with limited powers, it presented some interesting tax measures on Dutch budget day, Tuesday September 21, 2010. The package of law proposals for tax [...]

Switzerland, United Kingdom to Negotiate A Withholding Tax on Swiss-Based Assets

Switzerland and the United Kingdom have agreed to negotiate a new tax agreement that would require Swiss authorities to collect a withholding tax on the assets of U.K. nationals in Swiss banks and then transfer the receipts to the United Kingdom, the Swiss government announced Oct. 25. In a statement, the Swiss government said Swiss [...]

Swiss, German Officials Near Agreement To Begin Formal Talks on Double Tax Pact

GENEVA — Switzerland and Germany are close to an agreement allowing for negotiations on a new double taxation agreement that is likely to include provisions establishing a withholding tax on assets held by German nationals in Swiss banks. Mario Tuor, spokesman for the Swiss State Secretariat for International Financial Matters (SIF), told BNA Oct. 21 [...]

Energy tax incentive bill introduced in US Senate

Philip Tingle, Martha Pugh, Madeline Chiampou, Caroline Ngo and John Engel, McDermott Will & Emery LLP, New York, Washington DC and Miami New energy tax credit legislation was introduced by Senators Jeff Bingaman (D-NM) and Olympia J. Snowe (R-ME), under which natural gas, combined heat and power, the Advanced Energy Manufacturing Tax Credit, energy storage, [...]

Australia: Rio Tinto and BHP Billiton Approve Expansion Plans Despite Considering Abandoning Tax Agreement

Mining companies Rio Tinto and BHP Billiton both approved future expansion plans despite resuming talks looking at breaking their deal with the government over the terms of Australia’s new mining tax. Days after both companies were forced to abandon plans for a joint venture in the Pilbara region in northwestern Australia, Rio Tinto has approved [...]

Latest EU Effort to End Bank Secrecy With Automatic Information Exchange Fails

LUXEMBOURG — European Union efforts to establish a system of automatic information exchange of tax data and effectively end all bank secrecy in the EU hit a familiar roadblock Oct. 19 when Luxembourg and Austria were joined by a host of other European Union member states in opposing the legislation designed to combat tax fraud [...]

Philips Electronics Limited – consortium group relief

Peter Cussons, PricewaterhouseCoopers, London In August 2009, the First Tier Tribunal handed down its decision in favour of Philips Electronics Limited in their consortium group relief case. The two principal points at issue were: •  Firstly, the section 406(2) ICTA 1988 (Income and Corporation Taxes Act 1988) (now sections 133 and 134 CTA 2010) (Corporation [...]

China’s Tax System Going Green – an update

Alan Wu and Huili Wang, PwC, Beijing With the announcement made by China State Council in November 2009 that China will cut carbon dioxide emissions per unit of Gross Domestic Product by 40 percent to 45 percent by 2020 compared with 2005 levels, China’s efforts to deal with global climate change is once again brought [...]

Cognitive Capture, Parliamentary Parentheses, and the Rise of Fractional Apportionment

Stanley I. Langbein, Esq.  Professor of Law, University of Miami This article responds to recent scholarship, and the recent work of the European Commission of the European Union, advocating the use of “formula apportionment,” or “fractional apportionment,” as opposed to the “arm’s-length” method in allocating the tax base generated by transnational corporations (TNCs). Historically, the [...]

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