Sara Luder of Slaughter and May looks at the new tax arbitrage rules in Finance (No. 2) Act 2005
Simon Whitehead, partner, Dorsey & Whitney, discusses the pending European cases involving the tax treatment of transactions with companies with their seat outside the EU
In the light of the recent Marks & Spencer case, John Cullinane, Tax Partner at Deloitte, offers an alternative way forward
David Blumenthal, Partner, Dewey Ballantine, reports on the LexisNexis Corporate International Tax Planning conference held in February 2005
Paul Long, Tax Partner, KPMG and Trevor Hails, Chief Accountant, London Branch, Banco do Brasil and BTC Committee member, discuss the current status on taxation of branch capital
Chris Morgan, Head of KPMG's EU Tax Group, and Jonathan Bridges, Senior Manager in KPMG's EU Tax Group, outline how EU claims are now being extended to EU/non-EU transactions
Once a tax haven for interest expenses, France has recently experienced a significant tax audit activity in this area. Frédéric Laureau, Partner at EY Law in Paris, outlines what could become the new legislation
Annabelle Bailleul and Philippe Juilhard of CMS Bureau Francis Lefebvre discuss the changes introduced by the New UK/France Tax Treaty
Philip Martin once again provides us with his very personal opinions. In this article he looks at the Revenue's 'amnesia' as regards challenges under EC Law