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Global Tax Alert archives

Our archive of global tax alerts provide commentary and analysis on tax developments affecting cross-border transactions as they occurred. Visit the Global Tax Alerts page for current year alerts.

You may also subscribe to receive an email when a new alert is issued.

         Global Tax Alert archives
Date Country Development
23 Dec 11 Denmark High Court rules for taxpayer in beneficial ownership case
22 Dec 11 France Parliament approves change to transfer tax base on acquisition of shares in property-rich companies
21 Dec 11 Australia Government announces final stage of investment manager regime
18 Dec 11 France New proposal would eliminate cap on registration duty on sale of shares
17 Dec 11 Japan Proposal to limit interest expense deductions paid to foreign related parties
16 Dec 11 United States Temporary regulations under §954(d) branch rules finalized
9 Dec 11 France New restrictions on deduction of interest expense linked to acquisition of shares confirmed
6 Dec 11 Ireland Budget 2012
6 Dec 11 United Kingdom Draft legislation on CFC reform issued
6 Dec 11 Norway Supreme Court rules for Dell in agency PE case
6 Dec 11 Brazil New incentives on financial transaction tax announced
5 Dec 11 Japan Corporate tax rate reduction, WHT increase enacted
30 Nov 11 European Union ECJ rules Dutch exit charge is disproportionate and infringes EU law
18 Nov 11 France Large taxpayers may face increased advance payments due to tax law changes
16 Nov 11 Japan Two-phase 5% point corporate tax rate reduction proposed
8 Nov 11 France Surcharge to be levied on corporate income tax liability
8 Nov 11 United States IRS issues proposed §892 regulations
28 Oct 11 Australia ATO finalizes views on source/tax treaty look through approach to private equity investment
27 Oct 11 United States Representative Camp releases draft bill rewriting the U.S. tax rules on foreign income of U.S. multinationals
21 Oct 11 European Union German WHT on dividends paid to EU/EEA minority shareholders violates free movement of capital
19 Oct 11 OECD OECD proposes changes to Commentary on PE definition in Model Tax Convention
19 Oct 11 France Anti-abuse measure on deductibility of loan interest proposed
17 Oct 11 Hungary Extensive changes proposed to tax regime
26 Sep 11 United States White House releases draft statutory language on growth plan
20 Sep 11 United States President submits deficit reduction plan to supercommittee
20 Sep 11 Netherlands 2012 tax proposals limit interest/loss deductions and codify ruling practice
14 Sep 11 France Rules on corporate tax losses and long-term capital gains revised
7 Sep 11 United States IRS rules that U.K. Remittance Basis Charge is creditable
6 Sep 11 Switzerland WHT proposed to be abolished on some debt instruments held by foreign investors
25 Aug 11 Canada New foreign affiliate proposals on distributions, reorganizations and other transactions
24 Aug 11 Spain Changes made to corporate income tax and VAT rules
22 Aug 11 Canada Finance introduces new rules on repatriation from foreign affiliates, including loans of taxable surplus
11 Aug 11 United Kingdom Courts rule on availability of double taxation relief
9 Aug 11 Brazil New tax incentives announced
1 Aug 11 Brazil Tax treatment and regulatory procedures of derivative transactions changed
22 Jul 11 Peru New law clarifies scope of capital gains tax on indirect transfers
1 Jul 11 United Kingdom Consultation document on CFC rules issued
23 Jun 11 Taiwan Guidance issued on thin capitalization rules
19 Jun 11 Qatar Regulations issued under 2009 income tax law
2 Jun 11 Italy Tax authorities supplement guidance on CFC rules
31 May 11 United States IRS issues final “Killer B” regulations under §367(b)
25 May 11 Australia Reportable tax positions schedule being developed
19 May 11 Brazil Thin cap rules clarified
19 May 11 United States Potential U.S.-Poland treaty missing from Senate treaty hearing agenda
17 May 11 Malta Guidance issued on hybrid loans
29 Apr 11 France SICAV transparency on distributions extended to nonresidents
20 Apr 11 Canada Glitch will delay ratification of many TIEAs
15 Apr 11 United States IRS finalizes rules on foreign tax credit separate limitation categories
14 Apr 11 Netherlands New corporate income tax changes announced
12 Apr 11 United States Treasury provides new guidance on foreign account tax compliance (“FATCA”)
8 Apr 11 Taiwan Proposed hike in surtax will increase tax burden
7 Apr 11 Brazil “Short-term” loan period lengthened for purposes of financial transactions tax
1 Apr 11 Luxembourg Tax credit extended to qualifying investments in EEA countries
31 Mar 11 Norway Government proposes new rules on tax-exempt cross-border restructuring
30 Mar 11 Brazil Financial transactions tax increased on short-term loans and credit card debt
23 Mar 11 Mexico Proposed tax reform for 2013 includes repeal of flat tax
24 Feb 11 Australia Draft legislation released on reform of foreign-source income deferral rules
22 Feb 11 Peru VAT, Financial Transaction Tax rates lowered
17 Feb 11 Peru Capital gains tax rules on indirect transfers tightened
17 Feb 11 Kuwait Executive Rules amended and clarified
15 Feb 11 United States Treasury Department releases descriptions of international tax proposals in Greenbook
14 Feb 11 United States Administration releases FY2012 Budget
8 Feb 11 United States New excise tax hits foreign contractors
28 Jan 11 Denmark Taxpayer loses in third beneficial ownership case
25 Jan 11 Japan Proposed corporate tax rate reduction by 5% under 2011 Tax Reform
18 Jan 11 Colombia Tax on net equity introduced, financial transactions tax being phased out
13 Jan 11 Peru Withholding tax rules on payments to nonresidents revised
10 Jan 11 Spain Treaty with Costa Rica in effect
6 Jan 11 Brazil Incentives for long-term financing introduced and IOF rates revised
4 Jan 11 Taiwan New excise tax hits foreign contractors
3 Jan 11 Taiwan Treaty with Hungary in effect