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Global Tax Alerts

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DateCountryIssue
1 July 2009HungaryParliament passes major changes to tax rules 
25 June 2009Gibraltar2009 budget includes further tax reductions... 
24 June 2009BelgiumCircular issued on participation exemption 
22 June 2009IcelandNew proposed tax changes presented to Parliament 
22 June 2009VietnamPersonal income tax exemption introduced for 2009 
16 June 2009NetherlandsMinistry of Finance issues long-awaited interest box proposals
16 June 2009United StatesU.S.-Hungary treaty update
16 June 2009European UnionECJ rules on Dutch dividend withholding tax exemption
12 June 2009CyprusTax treaty update: Agreements with Italy and Czech Republic
11 June 2009OmanNew income tax law introduced
8 June 2009ItalyCorporate income tax refund opportunity available
28 May 2009DenmarkTax reform enacted
26 May 2009HungaryNew tax treaty initialed with U.S.
23 May 2009CanadaTIEA negotiations underway
23 May 2009HungaryGovernment proposes major changes to tax rules
12 May 2009United StatesTreasury Department releases Greenbook
7 May 2009ChinaNew M&A tax rules issued
7 May 2009IrelandNew tax relief granted on provision or acquisition of intangible assets
4 May 2009United StatesAdministration provides additional detail on international tax revenue raisers
4 May 2009SpainRules on taxation of nonresidents without PE in Spain to be amended
1 May 2009United StatesU.S. tax treaty update
28 April 2009IcelandParliament approves new CFC regime
23 April 2009Cyprus/RussiaNew protocol to Cyprus-Russia tax treaty and removal from Russian “blacklist”
17 April 2009NetherlandsAdministrative decree eases loss relief procedures
16 April 2009IndiaSupreme Court rules withholding tax mandatory on overseas salary for services rendered in India
13 April 2009Ireland2009 Budget Introduced
26 March 2009GermanyChange-in-ownership rule and interest deduction limitation rules may be relaxed
16 March 2009SwedenCourt allows deduction for cross-border group contributions
13 March 2009United StatesTreasury finalizes the §367(a) regulations on gain recognition agreements
6 March 2009United StatesCongress considers revised version of the Stop Tax Haven Abuse Act
6 March 2009KoreaMOSF announces new measures to improve foreign currency liquidity
6 March 2009NetherlandsSupreme Court considers protective assessment compatible with EC law
27 February 2009United StatesObama administration releases budget outline
27 February 2009NorwayLimited loss carryback for 2008/2009 approved
25 February 2009Hong Kong2009/2010 Budget offers medium-term good, but falls short on immediate measures
20 February 2009BelgiumEuropean Commission challenges certain restrictions of notional interest deduction regime
18 February 2009MaltaAcquisition and disposal of distressed assets resulting from global financial crisis
12 February 2009IndiaMumbai tribunal rules on installation PE
12 February 2009European UnionECJ rules Belgian participation exemption regime incompatible with Parent-Subsidiary Directive
11 February 2009LiechtensteinComprehensive draft revision of Tax Act published
6 February 2009NamibiaWithholding tax on interest to be introduced
6 February 2009IndiaITAT rules Indian sub of listed foreign company entitled to loss carryforwards
30 January 2009NorwayGovernment proposes loss carryback for 2008/2009
30 January 2009IndiaTribunal rules subsidiary conducting business with assistance of parent does not constitute PE of parent
23 January 2009United StatesProtocol to U.S.-France tax treaty signed
21 January 2009NetherlandsSupreme Court rules on “liability-to-tax” requirement
18 January 2009TaiwanFive-year tax holiday offered to encourage new investment
15 January 2009FranceNew protocol to U.S. treaty eliminates withholding tax on qualifying dividend distributions
15 January 2009KoreaMOSF issues notice on charge-back of stock option costs
12 January 2009EstoniaIncome tax and VAT changes effective
30 December 2008United StatesSubpart F contract manufacturing regulations go final (and temporary)
23 December 2008United StatesIRS issues proposed regulations on the application of conduit rules to disregarded entities
23 December 2008CyprusNew guidance provides certainty for tax-free treatment of profits and gains on disposals of securities
22 December 2008United KingdomHMRC releases draft legislation and guidance on pre-budget report items
22 December 2008GibraltarMajor win for Gibraltar in ECJ case
19 December 2008JapanTax reform proposals 2009 presented
18 December 2008FranceCash acceleration opportunities under recovery plan
16 December 2008LuxembourgMajor reform measures approved
16 December 2008United StatesProtocol with Canada and treaties with Bulgaria and Iceland enter in force
13 December 2008CanadaAdvisory panel issues report on international tax rules
11 December 2008TaiwanMOF ruling further clarifies calculation of taxable income in merger transactions
11 December 2008NetherlandsNew legislation may subject private equity managers to Dutch tax
10 December 2008FranceGovernment announces refund of R&D credits in 2009
9 December 2008IndiaVodafone writ in capital gains tax liability case rejected
8 December 2008United KingdomCourt rules on double tax position of hybrid entities
3 December 2008European UnionECJ rules French group consolidation rules incompatible with EC treaty
28 November 2008IcelandCentral bank issues foreign exchange regulation
25 November 2008United KingdomPre-budget report includes foreign profits reforms
25 November 2008AustraliaATO scrutinizing arrangements to avoid capital gains tax
19 November 2008SpainTreaty with Colombia enters into force
11 November 2008NorwayExtended exit taxation proposed
30 October 2008United StatesPetitions to avoid loss of GSP duty-free treatment due by 13 November
24 October 2008LuxembourgLaw to reform chamber of commerce contribution announced
23 October 2008United StatesStatus update to the pending 1999 U.S.-Italy treaty and protocol
23 October 2008AustraliaCourt confirms protection from Australian CGT under treaty with Switzerland
20 October 2008European UnionECJ concludes Dutch restrictions on mortgage interest deduction incompatible with EC law
16 October 2008ChinaDebt-to-equity ratio prescribed for thin capitalization rules
15 October 2008IndiaInbound and outbound expatriates required to contribute to provident fund/pension scheme
9 October 2008DenmarkTax minister presents draft corporate tax changes
8 October 2008United StatesInternational tax provisions in emergency $700 billion “bailout”
7 October 2008NorwayGovernment proposes to reduce participation exemption benefit
6 October 2008United StatesIRS responds to liquidity crisis in notice 2008-91 – Modifies definition of "obligation"
3 October 2008UK/NetherlandsNew tax treaty signed
1 October 2008LuxembourgDraft bill would eliminate withholding tax on dividends
1 October 2008NetherlandsMutual agreement decree issued and revised arbitration article included in new treaty with UK
22 September 2008HungaryGovernment unveils proposed tax changes
18 September 2008SwitzerlandMeasures announced to attract hedge funds and private equity
18 September 2008IndonesiaGuidance issued on definition of beneficial owner for treaty purposes
12 September 2008United StatesIRS to automatically assert penalties on untimely filed form 5471
12 September 2008AustraliaATO provides guidance on foreign branch income exemption for investments through U.S. llcs
9 September 2008European UnionECJ AG Kokott opines on French group taxation
4 September 2008LuxembourgDraft bill on abolition of capital duty issued
3 September 2008SwedenGovernment proposes limits on interest expense deductions
2 September 2008CyprusTax law amended to allow for exchange of information under tax treaties
25 August 2008AustraliaATO targets outbound structures 
22 August 2008NetherlandsSupreme court rules on dividend withholding tax exemption 
21 August 2008AustraliaATO to target international tax issues in FY2009 
4 August 2008United KingdomConsultation paper issued on deductibility of interest payable to connected parties 
31 July 2008NetherlandsFiscal unity rules on cross-border group taxation referred to ECJ 
28 July 2008GermanyFinal guidance issued on new change-in-ownership rule
24 July 2008United StatesU.S. Treasury technical explanation provides guidance on proposed U.S.-Canada protocol (part 2)
18 July 2008OECDOECD releases Commentary to 2008 Model Treaty
16 July 2008United StatesTemporary foreign tax credit regulations issued on structured passive investment arrangements 
15 July 2008SwitzerlandGuidelines published for application of law on regional policy
15 July 2008OECDOECD releases new article 7 draft
10 July 2008United StatesTreasury technical explanation of proposed U.S.-Canada protocol released
10 July 2008IndiaAAR rules referral fees paid to nonresident group company not taxable in India
7 July 2008United KingdomHigh court rules in Vodafone that U.K. cfc rules incompatible with EC law
2 July 2008European UnionECJ rules on concept of withholding tax under EC Parent-Subsidiary Directive
2 July 2008IndiaTribunal holding further muddies reimbursement of expenses subject to withholding tax
27 June 2008European UnionAG Mengozzi concludes Dutch restrictions on mortgage interest deduction incompatible with EC law
20 June 2008FranceNew tax treaty with U.K. signed
19 June 2008AustraliaNew opportunities and challenges for managed investment trusts
16 June 2008VenezuelaTax on financial transactions repealed 
4 June 2008AustraliaATO issues guidance on classification of Delaware limited partnership as foreign hybrid limited partnership
2 June 2008IcelandParliament approves major amendments to income tax act
29 May 2008European UnionDutch withholding tax rules as applied to FIIs partially incompatible with EC law
25 May 2008NorwayEFTA court rules on Norwegian tax credit 
23 May 2008LuxembourgAbolition of capital duty and corporate rate reduction announced
22 May 2008European UnionECJ confirms rulings relating to U.K. taxation of foreign dividends and CFCs
16 May 2008ItalyAuthorities rule on application of CFC rules in black list country
16 May 2008European UnionECJ upholds nondeductibility of foreign PE losses at level of head office
15 May 2008AustraliaATO provides positive guidance on tax treatment of Dutch pension pooling funds investing in Australia
14 May 2008European UnionAG Sharpston opines Belgian DRD incompatible with EC Parent-Subsidiary Directive
28 April 2008CanadaTax court addresses issue of beneficial ownership under Dutch tax treaty
25 April 2008OECDOECD releases draft changes to model treaty
23 April 2008TaiwanTax consequences of service charges paid to foreign securities brokers clarified
21 April 2008FrancePrivate letter ruling confirms applicability of R&D tax credit 
21 April 2008TaiwanMOF rules on availability of creditable tax to foreign shareholders 
17 April 2008EstoniaCorporate tax law changes effective in 2009
16 April 2008DenmarkBill introduced to close international tax loopholes
14 April 2008FranceGuidance issued on avoiding challenge to capital gains tax
8 April 2008European UnionECJ rules on French social security levies 
4 April 2008SpainNational court rules on nature of evidence to support intragroup services 
3 April 2008ChinaNew enterprise income tax filing and payment requirements for branches 
28 March 2008GermanyCourt holds no taxing rights on payments to U.S. resident partners 
20 March 2008AustraliaATO rules on tax treatment of Dutch co-operative association 
20 March 2008FranceTribunal rules on EC directive's anti-abuse rule in context of withholding tax exemption 
13 March 2008TaiwanFinance Ministry issues tax ruling on M&A 
12 March 2008United KingdomBudget 2008 announced 
11 March 2008European UnionGerman treatment of exchange rate losses on repatriation of PE’s start-up capital violates EC treaty 
4 March 2008India2008 budget contains few benefits for companies 
3 March 2008TaiwanMOF clarifies calculation of taxable income in cash merger 
29 February 2008United StatesProposed CFC contract manufacturing regulations released 
29 February 2008CanadaBudget will ease compliance requirements for nonresident investors 
27 February 2008European UnionECJ requires interest to be paid for unnotified state aid 
25 February 2008SwitzerlandSwiss corporate tax reform II approved by public vote 
25 February 2008LuxembourgMeasures introduced to enhance SICAR regime 
22 February 2008European UnionECJ AG Sharpston opines on German denial of foreign PE loss deduction 
19 February 2008United StatesThird circuit reinstates regulation requiring timely filing for ECI expenses
13 February 2008TaiwanRulings grant tax incentives for attracting foreign professionals
8 February 2008MexicoFlat tax may violate constitution
29 January 2008European UnionECJ strikes down Belgian rules on reclassification of interest
28 January 2008Customs International TradeCBP proposes major changes to interpretation underlying first sale for export duty-savings benefits
18 January 2008United StatesTemporary foreign tax credit regulations provide needed ODL guidance
17 January 2008BrazilFinancial transactions tax abolished and other recent changes
12 January 2008FranceGuidance on thin capitalization rules published
11 January 2008Portugal2008 budget law includes measures affecting payments to nonresident entities
10 January 2008BelgiumRuling commission issues guidance on dividends received from Hong Kong
8 January 2008United StatesWithholding tax provisions under newly in force treaty agreements
2 January 2008KuwaitIncome tax law amended
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Page Last Updated: July 1, 2009
Source: Deloitte Touche Tohmatsu (English)

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