On 1 January 2009, the transition period granted to Estonia for harmonising the Income Tax Act with the EU Parent-Subsidiary Directive will come to an end. The Estonian Income Tax Act does not tax the income earned by companies upon its receipt, but rather upon distribution. Hence, it is disbursements, including dividends that are subject to taxation. However, the directive prohibits the subjecting to income tax of profit distributable by a subsidiary of one member state to a parent of another member state, if the parent’s holding in the subsidiary is greater than 10% as of 1 January 2009.
Automatic transposition of the tax exemption specified in the directive, to the current Estonian taxation system, would mean that the income of a company which is owned by a company of another member state would not be taxed in Estonia, neither upon its receipt nor upon its distribution as dividends to a parent undertaking of another member state....
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On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contracts (which the court calls "PVFCs") and associated stock lending agreements ("SLAs") with respect to portfolio stock (indirectly) owned by him.
Recent statements by Prime Minister Kevin Rudd’s government to impose a super tax of 40% on profits of mining projects in Australia from July 2012, have created much consternation among mining executives and investors in Australian mining companies.
HMRC has published online guidance on their complaints handling procedure, covering Preventing Complaints, Standards for Dealing with Complaints, Recognising and Defining a Complaint, Avenues for Complaints Recording Complaints, Dealing with Complaints, Cross Business Complaints, Complaints about Staff Conduct, Persistent and Vexatious Complaints, Complaints received via Elected Representatives, Complaints to the Chairman or Ministers, Complaints to the Adjudicator's Office, Complaints to the Pa
The standard corporate tax rate applicable to companies registered in Malta is 35% and there are no thresholds for reduced rates of taxation applicable.
There have been no specific new Court decisions on Residence in the UK over the Summer. However, on 16th August 2010 (via a Press Release on Robert Gaines-Cooper’s own website) there was confirmation that he has been granted leave to Appeal to the Supreme Court in his Judicial Review Claim against HMRC.
Following the High Court decision in Bamford, we have reviewed a lot of unit trust deeds and have seen many unit trusts with superannuation funds as unitholders.
