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May 2008
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Book
This paper discusses the tax issues for business arising out of the emissions trading scheme.
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May 2008
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Book
This paper sets out the basic building blocks required to understand the TOFA regime - and in particular focus on the dividing line as to when the rules will apply.
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This contains updates and most relevant issues for proper compliance with statutory Transfer Pricing provisions.
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October 2009
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Client/Legal Alert
The Australian Assistant Treasurer, Senator Nick Sherry has announced that Australia and Guernsey have today signed a new tax information exchange tax agreement (TIEA).
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Learn more about the Basic Structure of the Tax Laws in the Region, such as: Value Added Tax, Income tax, Asset taxes that Back up the Income Tax, Payroll taxes, Financial transactions taxes and bank debit taxes, Real Estate transfer taxes, Gross revenue, Stamp taxes, and Custom duties and fees.
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Featured Content
Bogota, Colombia, August, 2010 - Baker & McKenzie has advised Frontino Gold Mines Limited ("FGM"), the owner of one of the largest gold mines in Colombia, on the sale of its assets of to Zandor Capital S.A. Colombia. The transaction value was over USD200 million.
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6 September 2007
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Client/Legal Alert
On August 29, 2007, the District Court for the District of Rhode Island issued its long anticipated opinion in United States v. Textron Inc., 2007 U.S. Dist. LEXIS 63921 (D. R.I. August 29, 2007).
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This contains resources for the 11th Annual Latin American Tax Conference's Breakout Session 2.
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May 2008
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Client/Legal Alert
This paper highlights the application of demerger CGT rollover relief has been highlighted in a number of high profile transactions. Interesting issues arise particularly where demerger relief is sought to be obtained in conjunction with other CGT rollovers (particular CGT scrip-for-scrip rollover).
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January 2009
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Client/Legal Alert
Treasury issued final/temporary regulations under Internal Revenue Code Section 954, covering contract manufacturing as it relates to the manufacturing exception to subpart F and the application of the associated manufacturing branch rule. These regulations represent important guidance regarding when a controlled foreign corporation can take advantage of the manufacturing exception by making a "substantial contribution" in a (related or unrelated) contract manufacturing arrangement. They also potentially apply to groups whose controlled foreign corporations have been structured into unrelated-to-unrelated transactions, thereby potentially introducing manufacturing branch rules issues into those structures.
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October 2009
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Client/Legal Alert
On 21 October 2009, the Government introduced into Parliament legislation to reform the taxation of employee share schemes.
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This contains resources from the 11th Annual Latin American Tax Conference's Breakout Session 1.
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This contains resources on the 11th Annual Latin American Tax Conference's Breakout Session 3.
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May 2008
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Client/Legal Alert
The concept of international trade has existed for centuries. In the 21st century, its striking feature is the rise of international trade between related parties. Multinational enterprises (MNEs) have expanded around the globe, establishing subsidiaries, branches and offices in foreign jurisdictions. In the process of establishing wider procurement and distribution networks and ultimately profitability, these MNEs inevitably trade with related parties.
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October 2011
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Newsletter
The newsletter provides an overview of the tax treaty between Germany and Switzerland. The treaty will enable the two countries to resolve longstanding disputes over assets managed by Swiss banks.
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