tax notes international - Tuck School of Business - Dartmouth College

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369 371 376 380 381 383 IN THIS ISSUE by Cathy Phillips HIGHLIGHTS Minding the Book-Tax Gap by Joann M. Weiner Multinationals Accumulate to Repatriate by Lee A. Sheppard and Martin A. Sullivan U.S. Widens Investigation of Swiss Bank by Randall Jackson Indian Supreme Court Denies Vodafone Appeal by Kristen A. Parillo AP Photo/Martin Meissner Canadian Budget Delivers Outbound Tax Relief by Steve Suarez 387 COUNTRY DIGEST FEATURED PERSPECTIVES 411 Buddy, Can You Spare a Dime? by Trevor Johnson 415 BOOK REVIEW The Global Tax Revolution: The Rise of Tax Competition and the Battle to Defend It 417 419 421 447 PRACTITIONERS’ CORNER New Rules for Valuing Intangible Assets In Spain by Sonia Velasco and Ana Colldefors Deduction of School Fees Under German Law by Marko Wohlfahrt and Katrin Köhler SPECIAL REPORTS Different Methods of Attributing Profits To Agency PEs by Carlos Eduardo Costa M.A. Toro U.S. Tax Review by James P. Fuller 475 CALENDAR ON THE COVER Minding the Book-Tax Gap. . . . . . . . . . . . . . .371 U.S. Widens Swiss Bank Probe . . . . . . . . . . . .380 Indian Supreme Court Denies Vodafone Appeal . . . 381 U.S. Companies Facing Chinese Compliance Burdens. . . . . . . . . . . . . . . . . . . . . . . .389 Treatment of Intangibles in Spain. . . . . . . . . . .417 Attributing Profits to Agency PEs. . . . . . . . . . .421 Multinationals Accumulate to Repatriate . . . . . . .376 Cover photo: Newscom TAX NOTES INTERNATIONAL FEBRUARY 2, 2009 • 367 (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
ARGENTINA 387 Buenos Aires’ New Stamp Tax Triggered by Two Core Events BANGLADESH 388 Government Revokes Import Tax on Renewable Energy Imports CAMBODIA 388 Tax Breaks Targeted to Critical Garment Industry CHILE 389 Stimulus Package Wins Unanimous Approval CHINA (P.R.C.) 389 U.S. Companies Facing Compliance Burdens in China ECUADOR 390 Congress Approves Tax Package EUROPEAN UNION 391 Austrian Leasing Rules Incompatible With EC Treaty, ECJ Says GERMANY 393 Former Deutsche Post CEO Convicted Of Tax Evasion HAITI 394 Mobile Phone Service Providers Oppose Tax Hike HUNGARY 394 Employer Tax Cut, VAT Increase Under Consideration INDIA 395 Indian PE Not Responsible for Withholding, Tax Tribunal Says 396 Subsidiaries in India Do Not Constitute A PE, Tribunal Rules NEWS AT A GLANCE INDONESIA 397 Exit Tax Rules Revised 398 Regulation Amends CFC Rules, Clarifies Export Duty JAMAICA 399 World Bank Backs Jamaican Tax Reform Effort JAPAN 399 Consumption Tax Measure Advances MULTINATIONAL 400 IASB Rejects Proposal to Allow Discounting of Current Tax in IAS 12 NORWAY 401 Government Proposes Carryback Rule For Losses OECD 402 OECD Group Addresses CIVs, Cross-Border Investors PORTUGAL 405 Government Submits Budget Supplement RUSSIA 406 Court Dismisses Claim for Back Taxes Against Ernst & Young SPAIN 407 Directors’ Remuneration Not Deductible, Supreme Court Says SWEDEN 408 Government Proposes to Defer Employee Tax Payments UNITED STATES 408 Drafters of Temporary Branch Regs Defend Rules’ Complexity 368 • FEBRUARY 2, 2009 TAX NOTES INTERNATIONAL (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
Page 1: tax notes international Volume 53,
Page 5 and 6: President and Publisher: Christophe
Page 7 and 8: HIGHLIGHTS from the tax accounts in
Page 9 and 10: HIGHLIGHTS However, if the firm rec
Page 11 and 12: HIGHLIGHTS NEWS ANALYSIS Multinatio
Page 13 and 14: HIGHLIGHTS check by full tax on any
Page 15 and 16: HIGHLIGHTS U.S. Widens Investigatio
Page 17 and 18: HIGHLIGHTS is required to withhold
Page 19 and 20: HIGHLIGHTS by a Canadian taxpayer a
Page 21 and 22: HIGHLIGHTS Personal Tax Measures Th
Page 23 and 24: ARGENTINA the most significant exem
Page 25 and 26: CHINA (P.R.C.) On December 16, 2008
Page 27 and 28: EUROPEAN UNION ensure that there is
Page 29 and 30: GERMANY confessed to his wrongdoing
Page 31 and 32: INDIA Addressing the assessee’s d
Page 33 and 34: INDONESIA As of January 1 and conti
Page 35 and 36: JAPAN insistence that the bill incl
Page 37 and 38: OECD OECD OECD Group Addresses CIVs
Page 39 and 40: OECD Furthermore, a source country
Page 41 and 42: PORTUGAL Extension of Portuguese Ho
Page 43 and 44: SPAIN tax authorities interpret the
Page 45 and 46: 410 • FEBRUARY 2, 2009 TAX NOTES
Page 47 and 48: FEATURED PERSPECTIVES We, the taxpa
Page 49 and 50: FEATURED PERSPECTIVES he has to pay
Page 51 and 52: BOOK REVIEW smaller government. But
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418 • FEBRUARY 2, 2009 TAX NOTES
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PRACTITIONERS’ CORNER for German
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SPECIAL REPORTS reports were of the
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SPECIAL REPORTS that either avoids
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SPECIAL REPORTS U.S. Germany Switze
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SPECIAL REPORTS The operations carr
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SPECIAL REPORTS the profits that ma
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SPECIAL REPORTS In essence, the fir
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SPECIAL REPORTS Figure 6. Single Ta
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SPECIAL REPORTS Table 1. Comparison
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SPECIAL REPORTS Singapore India pre
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SPECIAL REPORTS such a case, the tr
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SPECIAL REPORTS If the single taxpa
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SPECIAL REPORTS agent would be as i
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446 • FEBRUARY 2, 2009 TAX NOTES
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SPECIAL REPORTS create unintended b
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SPECIAL REPORTS country of organiza
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SPECIAL REPORTS regulations make cl
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SPECIAL REPORTS manufacturing is th
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SPECIAL REPORTS FS A B C Designs X
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SPECIAL REPORTS are performed in Co
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SPECIAL REPORTS the intangible deve
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SPECIAL REPORTS In Example 3, the f
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SPECIAL REPORTS The investor model
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SPECIAL REPORTS The licensing alter
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SPECIAL REPORTS The second exceptio
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SPECIAL REPORTS provides the most r
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SPECIAL REPORTS The taxpayer assert
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SPECIAL REPORTS the elimination of
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TAX CALENDAR financially distressed
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Africa: Zein Kebonang Albania: Adri
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tax notes international - Tuck School of Business - Dartmouth College

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