December 2003

Issue

Date

Subject

2003-35

December 19, 2003

  • Croatia: Incentives for Research and Development
  • Germany: Supreme Tax Court Disallows NOL Carryforward for Direct Ownership Changes Within a Controlled Group of Companies
  • Luxembourg: Court Addresses Double Taxation Issues with Germany
  • Luxembourg: Draft Decree on VAT Exemption Relating to Services Rendered by Independent Groups to Their Members

2003-34

December 17, 2003

  • Germany: Tax Reform: 2003 Tax Preference Reduction Act – "Basket II"

2003-33

December 12, 2003

  • Bulgaria: Introduction of Tax Depreciation Schedule
  • Central Europe: Overview of Tax Rules for Property Investment in Six CEE Countries
  • European Union: Status of Implementation of the Acquis Communautaire
  • United Kingdom: Transfer Pricing, Thin Capitalization, and Other Business Taxation Proposals in the Pre-Budget Report 2003

2003-32

December 10, 2003

  • Finland: Reform of Company and Capital Income Taxation
  • Latvia: Draft Corporate Income Tax Declaration; New Requirements for Taxpayers
  • United Kingdom: Overview of Tax Measures in Pre-Budget Report 2003

2003-31

December 5, 2003

  • Ireland: Tax Incentives Included in Budget 2004 Proposals
  • Poland: Status of Tax Legislation Pending EU Accession

2003-30

December 5, 2003

  • Czech Republic: New VAT Reporting Requirements for 2004
  • European Union: ECJ Addresses State Aid and the Impact on Direct Tax
  • Germany: Tax Legislation Changes
  • Hungary: Tax Reforms to Dismantle Hungarian Offshore Company Regime
  • Italy: Real Estate Investment Fund Income to Be Taxed at Investor Level
  • .Poland: Proposed New VAT Law
  • United Kingdom: Inland Revenue Victory in Hoechst Litigation

November 2003

Issue

Date

Subject

2003-29

November 21, 2003

  • Czech Republic: Senate Approves Measure to Postpone Thin Cap Rules Amendment
  • European Union: Merger Directive
  • Luxembourg: Legislative Update
  • Luxembourg: Treaty Update
  • United Kingdom: Pre-Budget Report 2003
  • United Kingdom: Inland Revenue's Transfer Pricing Consultative Document
  • United Kingdom: Tax Overpaid in Earlier Years; Amendment to Proposed Legislation

2003-28

November 12, 2003

  • Czech Republic: Treaty Update, Legislation Proposing Reduced Taxation of Investment Income
  • Romania: Recent Business Law Developments
  • United Kingdom: Items Possibly to Be Included in Pre-Budget Report
  • United Kingdom: Simplified Import VAT Accounting Program to Take Effect in December 2003

2003-27

November 6, 2003

  • Belgium:New Regulation Reduces Period for Deducting Input VAT
  • Bulgaria: 2003 Supreme Administrative Court Decisions
  • Czech Republic: Legislative Proposals Would Affect Current and Future Manufacturing Investment Incentives
  • Germany: New Profit Determination Documentation Regulations for Transfer Pricing
  • Germany: Supreme Tax Court Allows NOL Carryover for Indirect Ownership Change in a German Corporation with NOLs
  • Ireland: Discussions of Irish Revenue Powers, Savings Directive, UK Stamp Duty

October 2003

Issue

Date

Subject

2003-26

October 30, 2003

  • Czech Republic: Effects of European Union Accession on "State Aid" Provisions
  • France: Proposed Tax Changes Submitted to Parliament
  • Italy: New Tax Incentives to Promote Corporate Investment
  • The Netherlands: New Rules for Holding Companies and Head Office Companies
  • United Kingdom: Inland Revenue Proposals to Repeal Transfer Pricing Exemption, Thin Capitalization Rules
  • United Kingdom: Is a Dividend a Transaction in Securities?
  • United Kingdom: Proposed Changes to Northern Ireland Rating System Would Increase Property Taxes

2003-25

October 16, 2003

  • France: Proposed Changes to Capital Gains Tax Rules on Sale of French Real Estate
  • Germany:Update on German Tax Reform – Latest Developments
  • Germany: Proposed Thin Capitalization Rules
  • Norway: No Further Tax Cuts in the Budget Proposal for 2004
  • Poland: Update on Special Tax Offices to Serve "Large Taxpayers"
  • Portugal: Proposals for Property Tax Reform
  • Romania: Goods Exempt from Import Duties

2003-24

October 8, 2003

  • Bulgaria: Double Tax Treaty Network
  • Czech Republic: Overview of Proposed Changes to Corporate Income Tax Act
  • Italy: Update on Corporate Tax Reform
  • Italy: Advance Pricing Agreement Procedures Are Introduced
  • The Netherlands: Proposed Legislation to Address Bosal Issues
  • United Kingdom: Ocι van der Grinten – Analysis of the Decision of the European Court
  • United Kingdom: Court of Appeal Holds on Liability of Traders for Excise Duty

September 2003

Issue

Date

Subject

2003-23

September 30, 2003

  • Czech Republic: Update on Merger Control Regulations
  • European Union: ECJ Clarifies Withholding Tax Under the Parent-Subsidiary Directive
  • Ireland: Squeezing Tax Cost
  • Luxembourg: Securitization Legislation Is Introduced
  • The Netherlands: EU Interest-Royalty Directive
  • Poland: Service Charges and Permanent Establishment
  • Portugal: Tax Reductions for the Free Zone of Madeira
  • United Kingdom: Implication of ECJ Decision in Bosal for Taxpayers in the UK, Other EU Member States
  • United Kingdom: Draft Regulations to Implement the EU Savings Directive
  • United Kingdom: Cancellation Payment for Share Options Retained on Redundancy

2003-22

September 19, 2003

  • Bulgaria: Currency Regime Changes
  • France: Unofficial Reports on Tax Measures to Be Included in 2004 Finance Bill
  • Italy: Final Version of Legislative Decree Is Approved
  • Luxembourg: Update on Savings Directive
  • Luxembourg: New Company Status Proposed for Certain Venture Capital or Private Equity Companies
  • The Netherlands: ECJ Issues Decision on Netherlands Participation Exemption Regime
  • Poland: Special Tax Offices Proposed to Serve "Large Taxpayers"
  • United Kingdom: Time Limits for Tax Claims – New Legislation to Counter Deutsche Morgan Grenfell
  • United Kingdom: EU Law Offers Possibility to Reclaim Surplus Advance Corporation Tax

2003-21

September 4, 2003

  • Germany: Change of Control Rules; Hearing before the Federal Supreme Tax Court
  • Germany: GermanNews
  • Italy: Proposed Introduction of Tonnage Tax
  • Poland: Draft of Amendments to the 2004 CIT Act
  • United Kingdom: Group Litigation Orders
  • United Kingdom: Capital Losses – Change of Inland Revenue Position

August 2003

Issue

Date

Subject

2003-20

August 22, 2003

  • Belgium: New Withholding Tax Exemptions for Belgian Holding Companies and Finance Companies
  • United Kingdom: Proposals for Reform of Corporation Tax
  • United Kingdom: Effect of Halladale Decision on Corporate Transaction Fees

2003-19

August 11, 2003

  • European Union: Proposals to Amend the Parent-Subsidiary Directive
  • Germany: Proposed Changes to German Trade Tax Law
  • United Kingdom: Different Tax Treatment of the Same Circumstances in Different Years
  • United Kingdom: Concerning Overseas Leasing – Legality Under EU Law of Restricted Capital Allowances

2003-18

August 6, 2003

  • Germany: Proposed Changes to German Tax Law

2003-17

August 1, 2003

  • Europe: KPMG's International Tax Centers to Hold Southeast Area Seminars
  • European Union: Proposal to Simplify Rules for Reduced VAT Rates on Goods and Services
  • Latvia: New Withholding Tax Rules on Payments to Non-Residents for Consulting Services
  • The Netherlands: Reform on Underperforming Loan Conversion Rules
  • Spain: New Tax Treaty Between Belgium and Spain
  • United Kingdom: High Court Decision Extends EU Claim Time Limits
  • United Kingdom: Inland Revenue Addresses European Savings Directive
  • United Kingdom: 100% Capital Allowances for Energy Saving Plant and Equipment

July 2003

Issue

Date

Subject

2003-16

July 25, 2003

  • Germany: Tax Changes for Foreign Real Estate Investment Funds Under the Proposed Investment Modernization Act
  • Luxembourg: Collateralized Fund Obligation Structures
  • The Netherlands: Update on Advance Pricing Agreement Procedures
  • Poland: VAT in 2004
  • United Kingdom: Defining Innovation – Consultation on Research and Development
  • United Kingdom: Fast Approaching Deadline for Making Election Concerning Certain Employee Share Acquisitions

2003-15

July 17, 2003

  • European Union: Report on Tax Legislation in Accession Countries
  • European Union: Frequently Asked Questions on VAT and e-Commerce Directive
  • Germany: Investment Modernization Act Is Proposed
  • Italy: Deadline for Tax Amnesties and Settlements Is Extended
  • Latvia: Changes to VAT Administration; Tax Relief in Free Ports and Special Economic Zones
  • Luxembourg: Update of Tax Legislation, Proposals to Change the Commercial Companies Law
  • The Netherlands: Update of Treaty Negotiations, Reports of Treaty Status
  • Sweden: ECJ Judgment on Swedish Tax Treatment of Certain Pension Costs for Employees
  • United Kingdom: Finance Act 2003
  • United Kingdom: National Insurance Contributions – Meaning of Gratuity for Purposes of NIC on Payment Made by Third Party
  • United Kingdom: High Court Issues Judgment on Deductibility of Abortive Acquisition Expenditures
  • United Kingdom: Changes to the Procedures for Issuing Corporation Tax Penalty Notices

June 2003

Issue

Date

Subject

2003-14

June 27, 2003

  • Czech Republic: Proposed VAT Amendments and Other Developments
  • Germany: Does Limitation on Input-VAT Deductibility for Entertainment Expenses Comply with EU Directive?
  • Italy: Overview of Corporate Tax Reforms
  • The Netherlands: ECJ to Issue Decision Concerning Deduction of Expenses Related to Foreign Subsidiaries; Discussion of Double Tax Relief
  • United Kingdom: PAYE/NIC: Draft Regulations on Mandatory Electronic Payment by Large Employers

2003-Special Edition

June 20, 2003

  • United Kingdom: Intangible Assets and the Finance Bill

2003-13

June 19, 2003

  • Czech Republic: Tax Reform Discussion Continues; Update on Foreign Exchange Differences
  • _13Germany.Germany: ECJ Judgment Clarifies Compatibility of Withholding Tax Imposed on Non-Residents and Free Movement of Services
  • Luxembourg: Updated International Tax Guide, Tax Proposals Announced, Other Developments
  • Poland: Deadline Approaches for VAT Refunds to Non-Resident Entities for 2002
  • United Kingdom: First-Year Allowances and Plant Hire
  • United Kingdom: Simplifying the Taxation of Pensions – Implementation Date

2003-Special Edition

June 6, 2003

  • Belgium: Implications of EcoFin Agreement for Companies in Belgium
  • Germany: German "Thin Cap" Rules No Longer Apply for Tax Residents of Other EU Member States
  • Luxembourg: Background on EcoFin Agreement; Implications for Companies Doing Business in Luxembourg
  • The Netherlands: Implications of EcoFin Agreement for Companies Doing Business in the Netherlands

2003-12

June 5, 2003

  • Belgium: Update on Status of Belgian Coordination Center Program
  • Germany-Poland: New Double Taxation Treaty
  • Italy: First Draft of Legislative Decree for Tax Reform
  • Poland: Pending Customs Procedure Changes
  • Spain: Follow Up on Changes to Spanish Non-Resident Income Tax Law
  • United Kingdom: Possible Effect of House of Lords' Decision on Disposal of Surplus Property
  • VAT: VAT Refund Deadline Approaches

May 2003

Issue

Date

Subject

2003-11

May 22, 2003

  • Czech Republic: Legislation for Implementation of EU Parent/Subsidiary Directive
  • France: Special Tax Regime for International Headquarters and Logistic Centers Found to Breach EU State Aid Rules
  • Germany: Potential Reimbursements Under Customs Law for "Separately Shown" Financing Interest
  • Italy: Parliament Approves Delegating Legislation for Tax Reform
  • Luxembourg: Recent Tax Developments Concerning e-Commerce
  • United Kingdom: European Group Relief – Marks & Spencer at the High Court
  • United Kingdom: VAT Decision in Water Hall

2003-10

May 8, 2003

  • Czech Republic: Adjustment to Receivables Related to Guarantees; Other Developments
  • Denmark: Final Guidelines Expected on VAT Exemptions for Financial Services
  • Germany: Under New Legislation, When Can a Partnership Function As Parent of an Organschaft?
  • Latvia: Changes Proposed to Property Tax Law
  • The Netherlands: Tax Authorities Introduce Transfer Pricing (APA) Pre-Filing Meetings, Procedural Changes
  • Poland: Timing of Tax Treatment of Certain Lease Terminations
  • Switzerland: Webcast Discussions Address Harmful Tax Competition Developments, Swiss Initiatives to Attract Businesses
  • United Kingdom: 2003 Finance Bill Proposes Loan Relationship Provisions
  • United Kingdom: Employee Share Plan Costs, Employee Share Acquisitions
  • United Kingdom: Customs Changes Included in Finance Bill

April 2003

Issue

Date

Subject

2003-09

April 24, 2003

  • European Union: Possible Customs Issues as 10 Countries Are Set to Join the EU
  • Germany: New Transfer Pricing Documentation Rules
  • Germany: Summary of Certain Business Provisions in Recent Tax Legislation
  • International Tax: Dallas Conference to Address What's New in International Tax
  • United Kingdom: Update on Stamp Duty / Land Tax
  • United Kingdom: VAT Provisions Affecting Businesses Dealing in Telephones, Computers, and Associated Equipment

2003-08

April 17, 2003

  • France: Implications of EU Law for Deductibility of Interest Paid by French Company to EU Parent
  • France: Limitations on Tax Treatment of Interest Paid to Shareholders in the Context of Cash-Pooling Agreements
  • Luxembourg: Update on Taxation on Disposal of Real Property
  • The Netherlands: Supreme Court Allows Claim to Deduct VAT on Costs Relating to Sale of Shareholding
  • Poland: Treaty Update, Bankruptcy Act, Health Insurance Measures
  • United Kingdom: Finance Bill Is Published
  • United Kingdom: R&D Tax Credits
  • United Kingdom: Update on Treatment of Capital Gains Tax for Share Options
  • United Kingdom: Employee Share Plans -- Budget Extends Scope of PAYE and NIC

2003 - Special Edition

April 11, 2003

  • Germany: Final Legislative Agreement Reached on 2003 Tax Reform Proposals

2003 - Special Edition

April 10, 2003

  • United Kingdom: Budget 2003: Comment and Analysis

2003-07

April 3, 2003

  • Czech Republic: Fixed Rate of Exchange; Possible Relief for Late Payments of Tax; VAT Amendment
  • European Union: EcoFin Short of Agreement on Tax Package
  • European Union: Advocate General's Opinion to the ECJ on Migration Exit Charges
  • .European Union: EU Company Taxation Consultations
  • Germany: Discussion of Legislative Corporate Tax Proposals Continues
  • The Netherlands: Agreement with United States Clarifies Treatment of Exempt Pension Funds
  • United Kingdom: Budget Predictions – Indirect Taxes and Employee Related Issues
  • United Kingdom: Limitations for First Year Allowances on Information and Communications Technology
  • United Kingdom: Inland Revenue Guidance on New Tax Treaty with United States

March 2003

Issue

Date

Subject

2003-06

March 20, 2003

  • Belgium: New General Tax Ruling System
  • Czech Republic: Possible Czech Implications of Lankhorst Decision
  • Germany: Legislative Update on Proposals to Amend Corporate Tax System in 2003
  • Ireland: Guidance for Investment in Ireland
  • Latvia: New Customs Regulations
  • Poland: Use of "Active Regret" Concept to Avoid Penalties for Correcting Tax Returns in 2003
  • Portugal: Tax Reductions for the Free Zone of Madeira
  • Switzerland: Update on EU Savings Directive
  • United Kingdom: Costs of an Aborted Acquisition

2003-05

March 6, 2003

  • Denmark: Danish Guidelines on Transfer Pricing Documentation
  • Europe: Side-by-Side Comparison of Holding Regimes in 11 European Countries
  • European Union: European Court of Justice Rejects Basis for Lessor's VAT Refund; Substance Over Form Controls
  • European Union: Checklist for Companies Doing Business in Eastern European Countries With Pending EU Accession
  • Germany: Proposed Corporate Tax Changes in 2003 German Tax Reform
  • Italy: Tax Amnesty Deadline Draws Near
  • The Netherlands: Methodology for Calculating Arm's Length Profits for Financing Transactions
  • Poland: Recent Decree Expands Exemptions and Withholding Obligations for Personal Income Tax
  • United Kingdom: Possibility of Recovery Under Thin Capitalisation Arguments

February 2003

Issue

Date

Subject

2003-04

February 20, 2003

  • Ireland: Finance Bill 2003 Is Published; Now Subject to Debate
  • Norway: Skauge Commission Proposes Significant Changes to Tax System
  • Poland: New Information Reporting Obligations
  • Sweden: Recent Developments Relating to Dividends and Gain/Loss on Shares Owned by Companies, Proposed CFC Legislation
  • United Kingdom: High Court Decides Tax Treatment of Corporate Shareholders on Share Repurchase

2003-03

February 6, 2003

  • European Union: Political Consensus Concerning the EU Tax Package
  • Germany: Recent Elections Are Expected to Result in Changes to Pending Tax Legislation
  • Germany: High Tax Court Notice Addresses Loss Utilization Rules Regarding Intercompany Transfer of Shares ("Change of Control")
  • Hungary: Tax Changes Related to EU Admission
  • Italy: New Amnesty Program for Potential Tax Liabilities of Italian Subsidiaries
  • Latvia: New VAT Declarations for 2003
  • Poland: Amendments to the Minimum Wage Law
  • Switzerland: Upcoming Roundtable Discussions of Tax and Business Opportunities for U.S. Businesses
  • United Kingdom: Dividends to Parent Companies in EU Member States
  • United Kingdom: Follow Up on Share Options
  • United Kingdom: Compensation for Early Payment of ACT on Dividends to Non-Resident Parents
  • United Kingdom: Inland Revenue Targets Transfer Pricing

January 2003

Issue

Date

Subject

2003-02

January 23, 2003

  • Germany: Possible Legislative Responses to European Court of Justice's Judgment on German "Thin Cap" Rules
  • Germany: High Tax Court to Decide Loss Utilization Rules Where There Has Been Intercompany Transfers of Shares
  • Italy: VAT Ruling for Non-Resident Companies Conducting Sales of Goods in Italy
  • Norway: Guide to VAT Provisions and Regulations
  • Poland: Tax Treaty Update
  • Poland: VAT Amendments, Tax Administration and Procedure Changes for 2003
  • Spain: Tax Changes Effective in 2003
  • Switzerland: Update on EU Savings Directive
  • United Kingdom: Determination of Gain/Loss on Exercise of Share Options
  • United Kingdom: Special Commissioners Deny Marks & Spencer's Group Relief Appeal

2003-01

January 3, 2003

  • Italy: Clarification of “Pro Rata” Rule for the Sale of Securities by Fiduciary Companies
  • Latvia: Tax Rate; Minimum Wage; VAT on Medicine; Tobacco and Alcohol Excise Tax; Treaty Update
  • Poland: Changes for 2003 to Tax Rules for Business Trip Expenses; Amendments to Copyright Law
  • Spain: Tax Treatment of Spanish Holding Company Regime
  • United Kingdom: Court of Appeal Addresses Leasing Arrangements as Capital Expenditures

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