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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.

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         Global Tax Alert archives
Date Country Development
21 Dec 12 Australia Government update on status of Investment Manager Regime
14 Dec 12 Denmark Parliament passes dividend anti-avoidance rules and exemption for capital gains on portfolio shares
14 Dec 12 France FTA comments on anti-abuse provisions relating to acquisition of participating shares
6 Dec 12 Brazil More revisions to IOF on “short-term" external loan transactions
5 Dec 12 Ireland 2013 budget announced
5 Dec 12 United Kingdom Autumn statement contains measures to encourage growth
20 Nov 12 Finland Changes proposed to Transfer Tax Act
16 Nov 12 Portugal New austerity measures affect nonresidents
13 Nov 12 European Union Finnish taxation of dividends paid to nonresident pension funds violates EU law
06 Nov 12 United States Year-end considerations for U.S. investment managers with ownership in foreign entities
01 Nov 12 Denmark New bill proposed to ease taxation of capital gains on portfolio shares
29 Oct 12 Canada “Upstream loan” rules and other foreign affiliate proposals reintroduced
18 Oct 12 Canada Budget proposals on foreign affiliate “dumping” again revised
4 Oct 12 Denmark New bill would tighten taxation of dividends
2 Oct 12 United Kingdom Tax authorities issue response document for withholding on interest payments
2 Oct 12 Finland MOF revises proposed intragroup interest deduction limitation rules
30 Sep 12 France Proposals for 2013 finance bill expected to increase corporate income tax burden
24 Sep 12 Austria EU/EEA companies may benefit from special dividend withholding tax refund procedure in “Denkavit” situations
20 Sep 12 Netherlands 2013 budget includes repeal of thin capitalization rules
20 Sep 12 Sweden Budget proposals contain further restrictions on deduction of interest on intragroup debt
10 Sep 12 United States IRS guidance addresses “legging out” of “qualified hedging transactions” under §988(d)
4 Sep 12 Brazil Government extends period to obtain federal tax incentives
27 Aug 12 Australia Parliament passes Investment Manager Regime legislation
16 Aug 12 Canada Government releases revised budget proposals on foreign affiliate “dumping”
27 Jul 12 Taiwan Capital gains tax introduced on sale of securities
17 Jul 12 United States IRS provides guidance on outbound transfers of intangible property
17 Jul 12 Spain Tax measures introduced to tackle economic crisis
12 Jul 12 Chile Argentina terminates treaty as from 2013
9 Jul 12 Brazil New reporting requirement for cross-border transactions involving services and intangibles
6 Jul 12 France New taxes proposed on businesses, banks and wealthy individuals
29 Jun 12 United States IRS issues final and proposed regulations on treatment of overall foreign and domestic losses and high tax kickout
27 Jun 12 Australia Government releases investment manager regime legislation
19 Jun 12 Brazil More changes to IOF on "short-term" external loan transactions
15 Jun 12 Denmark Parliament passes corporate income tax changes
8 Jun 12 United States Section 7874 regulations issued on substantial business activities
5 Jun 12 Netherlands New restrictions proposed on participation financing
1 Jun 12 Cyprus Parliament approves tax laws to promote foreign investment
23 May 12 Brazil Court rules payments for outbound technical services not subject to withholding tax
23 May 12 Denmark Authorities rule EU parent is beneficial owner of deemed dividends
18 May 12 Denmark New rules facilitate entry of foreign investment funds into Danish market
11 May 12 European Union Investment funds prevail in French withholding tax case before ECJ
11 May 12 United States Treasury creates new exception from §956 for certain swap payments by CFC dealers
25 Apr 12 Denmark Corporate income tax bill presented to Parliament
23 Apr 12 United States Regs expand reporting of bank deposit interest paid to nonresident aliens beginning 2013
16 Apr 12 Finland EBITDA-based limitation on related party interest proposed
05 Apr 12 Spain More tax measures introduced to tackle public deficit
30 Mar 12 Canada Budget measures impact investment in foreign affiliates and tighten thin cap limit
28 Mar 12 United Kingdom Consultation launched on income tax rules on interest
21 Mar 12 United Kingdom 2012 budget measures affecting foreign multinationals
12 Mar 12 Australia Second exposure draft of Investment Manager Regime released
12 Mar 12 Brazil "Short-term" loan period extended for purposes of financial transactions tax
2 Mar 12 Brazil Government revises definition of "short-term" for purposes of IOF on foreign loans
2 Mar 12 Australia Changes proposed to strengthen general anti-avoidance rule
28 Feb 12 Canada Velcro Canada wins beneficial ownership case
15 Feb 12 France-Germany "Green Book" on tax convergence published; German ruling coalition announces plan for further business tax reform
14 Feb 12 United States IRS amends application of Section 367 to Section 304 transactions
14 Feb 12 United States Administration FY2013 Budget and Treasury descriptions of international tax proposals (Greenbook) released
13 Feb 12 United States Temporary and proposed dividend equivalent regulations issued under §871(m)
13 Feb 12 United States Foreign tax credit splitter and technical taxpayer rules issued
9 Feb 12 Italy Optional exit tax deferral introduced for deemed gains on intra-EU/EEA migration
8 Feb 12 Ireland Finance Bill 2012 generally positive for companies
6 Feb 12 Italy Tax authorities further clarify rules on utilization of tax loss carryforwards
3 Feb 12 Germany Tax authorities issue guidance on amended anti-treaty shopping rule
24 Jan 12 India Vodafone – Supreme Court holds sale of shares outside India between nonresidents is not taxable
18 Jan 12 Denmark Tax authorities lose another beneficial ownership case
4 Jan 12 Spain Tax measures introduced to tackle public deficit
2 Jan 12 Finland Change-in-control rules referred to ECJ on state aid grounds

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