Italy: Government Weighs Two Strategies For Reducing Debt, Calming Investor Fears

ROME — Italy Aug. 12 revealed two main tax-related strategies as part of its overall effort to dramatically reduce the government’s debt and assuage investor fears that the country could be forced to default on its bond obligations. The European Central Bank Aug. 11 ordered Italy to reduce its budget deficit by an additional 45 [...]

Reform of tax Residency rules in the UK

Jeremy Cape and Helen Dayananda, SNR Denton, London I. Introduction The question of where a person is resident for tax purposes is fundamental in determining how they are taxed. As it has become increasingly normal to have connections with, and spend long periods in, more than one country, many people have found it hard to [...]

China: New treaty increases attractions of UK holding company structure

Jon Eichelberger, Jinghua Liu, Alex Chadwick, James Smith and Brendan Kelly, Baker & McKenzie Beijing, London and Shanghai This article examines the new tax treaty recently signed between the UK and China. I. Introduction The UK and Chinese governments signed a new double tax treaty at the end of June 2011. With no dividend withholding [...]

Spain: Government Decree Simplifies Tax Regime for Foreign Investment

MADRID — The Spanish government put into force a decree July 31 simplifying taxation for nonresident investments in fixed income financial instruments. Royal Decree 1145/2011, which the Council of Ministers approved July 29, took effect the day after its publication July 30 in the Boletin Oficial del Estado, Spain’s national register. The new rules modify [...]

The Shifting Paradigm in International Transfer Pricing Enforcement: Key IRS Implementation Challenges

Craig A. Sharon, Esq. Bingham & McCutchen LLP, Washington, D.C. This commentary examines the emerging new paradigm in IRS transfer pricing enforcement. The paradigm is based primarily on principles underlying the APA Program, where I served as Director (and in other capacities) until February 2011. Conceptually, the new paradigm offers potential benefits to both taxpayers [...]