Intertax 2007 - Abstracts

Intertax 2007
50d (3) EStG - entitlement to tax relief available to foreign companies: unofficial translation of the Federal Ministry of Finance Circular dated April 3, 2007 and Explanatory Notes.(Legislation)LawRansch, Ulrich, Littan, Sonja, John, Alexandra
AG concludes Dutch dividend withholding tax exemption incompatible with EC law.(Advocate General Mengozzi interprets European Union treaty)LawWeening, Gerben, van den Hurk, Hans, Korving, Jasper
Appellate court affirms foreign tax credit reduction from indirect subsidy.(MONTHLY FEATURES)(US Tax Scene)LawFuller, Thomas, Angle, Connie, Castanon, Richard
Article 24 (1) of the OECD Model Convention and the exclusion of MFN treatment - a comment on the OECD Public Discussion Draft.(Organisation for Economic Cooperation and Development Model Convention and Most Favored Nation treatment)LawZalasinski, Adam
A single European market with 25 different corporate taxes? Fiscal disparity in Spain with regard to its future in the European Union.LawCalvo, Marta Bengoa, Poncela, Ana Carrera, Fernandez, Adolfo Cosme
Back to BASIC - stages of international tax planning or: getting the grip on a rocky road.(benchmarking, analysis, strategy, implementation, compliance)LawKessler, Wolfgang, Eicke, Rolf
Belgian court requests ruling on whether tax relief under Parent-Subsidiary Directive requires full ownership of shares.(Court of Appeal of Liege)LawRainer, Anno, Renier, Philippe
Belgian dividend deduction system referred to ECJ.(European Court of Justice)LawRenier, Philippe
Belgium: attribution of profits to permanent establishment.(Report)LawWustenberghs, Tim
Burden and another v United Kingdom.(CASE LAW)(UK)LawElliot, Peter
Can procedural rules create obstacles to fundamental freedoms in European Law?LawFuruseth, Eivind
CFC rules go up in smoke - with retro effect.LawWerlauff, Erik, Ronfeldt, Thomas, Vinther, Nikolaj
Commission takes steps against withholding tax on outbound dividends.(European Commission)LawRainer, Anno
Common corporate consolidated tax base - don't forget the tax rates!(Editorial)LawSpengel, Christoph
Comprehensive approaches to company taxation in the European Union and cross-border corporate reorganizations.LawDurrschmidt, Daniel
Conference: 'Recent and Pending Cases at the ECJ on Direct Taxation', 15-17 February 2007, Vienna.(European Court of Justice)LawFontana, Renata
Conference Report: The EU and Third Countries: Direct Taxation, 13-14 October 2006, Vienna.(European Union)LawFontana, Renata
Corporate tax and the OECD.(Organization for Economic Cooperation and Development)LawMerks, Paulus
Cross-border trading in shares or participation in Spanish collective investment institutions: new Regime for accreditation of residence and provision of information.LawGiner, Luis Alfonso Martinez
Current scenario of the tax incentives in Brazil: a comparison based on the concepts of state aid in Europe and of the commerce clause in the United States.LawCatao, Marcos Andre Vinhas
ECJ allows application of German thin cap rules to interest paid to non-EU shareholder.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice decision on Germany's thin capitalization rule as it relates to non-European Union shareholders)(Case overview)LawRainer, Anno
ECJ confirms non-application of basic freedoms of EC treaty between EU company and its third-country branch.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice)LawRainer, Anno
ECJ requested to interpret merger directive in context of German requirement for double rollover of book value.(European Court of Justice)LawRainer, Anno
ECJ rules French restrictions on exemption from annual real estate tax violate EC Treaty.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice, European Community)LawRainer, Anno, Arras, Rachid, Keyhani, Sarvi
ECJ rules Hungarian HIPA may continue to be applied.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice, Hungarian local business tax)LawRainer, Anno
ECJ rules on Austrian treatment of income from non-EU countries.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice decision on Austria's tax policy for non-European Union member countries)LawWeening, Gerben, van den Hurk, Hans, Korving, Jasper
ECJ rules on Finnish intragroup transfers.(European Court of Justice)LawRainer, Anno
ECJ rules on tax deductibility of fees for foreign private schools.(MONTHLY FEATURES)(EC Tax Scene)LawRainer, Anno, Nakhai, Katja
ECJ to rule on deductibilty of donations to non-resident charities.(European Court of Justice)LawRainer, Anno
ECJ to rule on nondeductibility of write downs on shares in nonresident companies.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice)LawRainer, Anno
EC tax scene.Law 
EC tax scene: ECJ rejects claim by nonresident companies for UK tax credits.(European Constitution Treaty)(European Court of Justice )LawThommes, Otmar, Tomsett, Eric, Rainer, Anno, Roels, Jan, Weening, Gerben, van den Hurk, Hans
EC tax scene: ECJ rules French withholding tax on outbound dividends violates EC treaty.(European Court of Justice)(European Constitution Treaty)LawRainer, Anno
EC tax scene: ECJ rules on UK corporate taxation of foreign source dividends.(European Court of Justice)(Treaty establishing a Constitution for Europe)LawThommes, Otmar, Tomsett, Eric, Rainer, Anno, Roels, Jan, Weening, Gerben, van den Hurk, Hans
EC tax scene.(European Community)(EC Merger Directive and group interest box)LawRainer, Anno, Weening, Gerben, van den Hurk, Hans, Korving, Jasper
EC tax scene.(MONTHLY FEATURES)(European Community)LawRainer, Anno, Renier, Philippe
Equity substitution loans in German commercial, insolvency and tax law: current status in anticipation of modernization.LawKerssenbrock, Otto-Ferdinand
European Commission to investigate Spanish goodwill amortization on foreign shareholdings.(MONTHLY FEATURES)(EC Tax Scene)LawRainer, Anno
European legal order with no mercy for member states' budget concerns.LawThommes, Otmar
EVJ to answer further questions on Belgian dividend received deduction.(MONTHLY FEATURES)(EC Tax Scene)LawRainer, Anno
Expected and unexpected developments of European integration in the field of direct taxes.(Editorial)LawPistone, Pasquale
Exploring the boundaries of the application of Article 10(5) of the OECD Model.(Organisation for Economic Cooperation and Development)LawMadeira, Eduardo Arruda, Neves, Tiago Cassiano
Final Regulations issued on attributing E&P to stock of a foreign corporation.(earnings and profits)LawTuerff, Tim, Trump, Christopher, Halpern, Irwin, Moneymaker, Dirk
Fiscal state aid goes global.LawRossi-Maccanico, Pierpaolo
Flat-rate taxation based on cost-of-living expenditure - a profitable option for rich foreigners resident in Switzerland?(Report)LawKnirsch, D., Schanz, S.
Freedom of establishment in the EC economic partnership agreements: in search of its direct effect on direct taxation.(ARTICLES)(European Community)(Report)LawBezborodov, Sergey
Governance, tax schemes, and big business.LawFerrers, Tony
Group tax incentives under scrutiny: Dutch Interest box under investigation.(LEGISLATION)(THE NETHERLANDS)LawWeber, Dennis, Blokland, Gerard, Luja, Raymond
Improving the legitimacy of soft law in EU tax law.(European Union)LawGribnau, Hans
Investor-state disputes: the interface between treaty-based international investment protection and fiscal sovereignty.(ARTICLES)LawWalde, Thomas, Kolo, Abba
Italian tax treaties and domestic law: some remarks about the relationship between provisions on foreign tax credit.LawContrino, Angelo
Italy introduces rules on taxation of trusts.(LEGISLATION)LawGreco, Edward F.
Limitation of the temporal effects of judgments of the ECJ.(ARTICLES)(European Court of Justice)LawLang, Michael
Limitation on Benefits: from the US Model 2006 to the ACT Group Litigation.LawPlansky, Patrick, Schneeweiss, Hermann
Multinationals, enforcement covenants and fair share.LawHappe, Richard
New German tax rules on financing expenses.(German 2008 Business Tax Reform)LawScheunemann, Marc P., Muller-Duttine, Tino
Notable changes in the proposed indirect taxes through the Finance Bill 2007.(Finance Act in India)LawGovind, Har
Noteworthy fiscal and tax changes in India in the financial year 2006-07.LawGovind, Har
Preliminary questions referred to ECJ on Netherlands inheritance tax for non-residents.(CASE LAW)(THE NETHERLANDS)(European Court of Justice)LawWeber, Dennis, Blokland, Gerard
Proportionality of anti-avoidance and anti-abuse measures in the ECJ's direct tax case law.(measures for prevention of tax evasion and tax abuse under the direct tax case law of the European Court of Justice)LawZalasinski, Adam
Proposal for a pension model with a compensating layer.LawDietvorst, Gerry J.B.
Protocol to Canada treaty signed.(MONTHLY FEATURES)(US Tax Scene)LawFuller, Thomas, Cohen, Harrison, Slaats, Sandra
Report on the conference: 'EU-taxes'.(CONFERENCE REPORT)(Vienna University of Economics and Business Administration)LawHeidenbauer, Sabine, Piscopo, Ramona
Safeguarding VAT revenue via actual cost taxation with collection at source.(value-added tax)LawLohse, W. Christian, Gebauer, Andrea, Parsche, Rudiger
Some thoughts on further refinement of the concept of place of effective management for tax treaty purposes.(Report)LawBurgers, I.J.J.
Special commissioners withdraw reference to ECJ on CFC legislation.(European Court of Justice)(controlled foreign company)LawTomsett, Eric
Taxation of cross-border savings: options for reviewing the European approach.LawGlaser, Lars
Taxation of non-profit organizations with multinational activities - the Stauffer Aftermath and tax treaties.(Centro di Musicologia Walter Stauffer Foundation)LawEcker, Thomas
Taxes and the World Trade Organization.(ARTICLES)(Report)LawRosembuj, Tulio
Tax facilities for state-induced costs under the EC state aid rules.(European Community)LawHosson, Fred C. de
Tax treaties and the internal market in the new European scenario.LawPistone, Pasquale
Tax treatment of non-operating companies in Italy.LawSanti, Alberto, La Candia, Ignazio
The Agreement on the Free Movement of Persons and its potential impact on direct taxes systems of EU member states.(European Union, Swiss Confederation)LawAdamczyk, Lukasz
The amendment of Australia's domestic law after the Lamesa case: a lesson to be learned from Dutch case law.LawSnoeij, Richard
The discriminatory taxation of permanent establishments by the host state in the European Union: a too much separate entity approach.LawArginelli, Paolo
The effect of Community law on pre-accession tax treaties.(Articles)(European Community)LawPanayi, Christiana HJI
The effects of global and regional trade agreements on domestic tax law and bilateral tax conventions: proceedings of a seminar held at the 60th International Fiscal Association Congress.LawFarrell, Jennifer E.
The European Court of Justice on the Dutch Levy upon emigration of a substantial participation holder in a corporation.LawKort, J.W.J. de
The Luxembourg Administrative Court lodges a reference for a preliminary ruling with the European Court of Justice concerning the taxation on non-resident individuals.(Case Law)(LUXEMBOURG)LawElvinger, Andre, Richter, Dirk
The Masa Investment group as a "nec plus ultra" case for the application of the Europeam Convention on Human Rights to tax law?(Report)LawGreggi, Marco
The need for tax clarity and the application of the Acte Clair doctrine to direct taxes.LawPistone, Pasquale
The new Italian provision on the fiscal residence of foreign companies - the legislator's haste and Tax Authorities' "distractions."(Legislation)(ITALY)LawNanetti, Francesco, Mazzotti, Giulio
The OECD transfer pricing guidelines as a source of tax law: is globalization reaching the tax law?(Organization for Economic Cooperation and Development)LawCalderon, Jose
The procedural conditions for the implementation of tax treaty obligations under domestic law.LawLang, Michael
The protection of human rights and the rigt to a fair tax trial in the light of the Jussila case.(ARTICLES)LawGreggi, Marco
The taxpayer's rights and the role of the Tax Ombudsman: an analysis from a Spanish and comparative law perspective.(comparison of tax ombudsmen's role in dispute resolution in Spain and Europe)LawSerrano, Fernando
Thin capitalization Glo et al. - a thinly concealed agenda.(interpretation of European tax laws by the European Court of Justice)LawPanayi, Christiana Hjl
Towards a more comprehensive examination of the compatibility of indirect taxes with the internal market.LawSorensen, Karsten Engsig
Transfer pricing rules in the new Turkish Corporate Income Tax Act.(Report)LawOner, Cihat
U.K. House of Lords rules compound interest applies to ACT compensation claims.LawTomsett, Eric
US tax scene.LawFuller, Thomas, Angle, Connie
US tax scene.(amendment of "foreign base company (FBC) services income" regulations)LawCohen, Harrison, Tuerff, Tim, Danilack, Michael, Trump, Christopher
US tax scene: final portfolio interest exemption regulations released.LawFuller, Thomas, Sina, Jeremy, Renfroe, Diane
US tax scene: new treaty and protocol with Belgium signed.LawFuller, Tom, Van Hove, Pascal
US tax scene.(United States Treasury Department, Internal Revenue Services set rules)Law 
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