Lowtax Network
Content Update | Issue XLIII | 31 July 2008
ONLINE VERSION: HTTP://WWW.LOWTAX.NET/NEWSLETTER/CONTENT_UPDATE_XLIII.ASP

Dear Colleague,

This week:

I hope you find this update useful. Please remember that you can customise your mailing preferences by visiting your own profile page to choose from 29 offshore tax and law subjects in order to receive just the information you want. You can also unsubscribe completely by following the instructions at the bottom of this page.

Kind regards,

Kate James


Tax-News.com Headlines

WTO Talks End Without Agreement,
by Ulrika Lomas, Tax-News.com, Brussels
Thursday, July 31, 2008
WTO Director-General Pascal Lamy announced on Tuesday that ministers attending trade talks in Geneva had failed in their efforts to agree on blueprint agreements in agriculture and industrial products. [ FULL STORY ]
Court To Hear Evidence In Tesco Tax Avoidance Case,
by Robin Pilgrim, LawAndTax-News.com, London
Thursday, July 31, 2008
A High Court judge has ruled that the Guardian newspaper can file evidence which claims to show that UK retail giant Tesco set up a series of offshore holding companies to avoid paying UK corporate tax. [ FULL STORY ]
FATF Issues Mutual Evaluation Of Hong Kong,
by Mary Swire, for LawAndTax-News.com, Hong Kong
Thursday, July 31, 2008
The Financial Action Task Force (FATF) has completed an assessment of the implementation of anti-money laundering and counter-terrorist financing standards in Hong Kong, it was announced this week. [ FULL STORY ]
IMF Calls On Japan To Raise Consumption Tax,
by Mary Swire, Tax-News.com, Hong Kong
Wednesday, July 30, 2008
While welcoming the efforts being made by the Japanese government to balance its budget by 2011, the International Monetary Fund (IMF) said on Tuesday that consumption tax may have to be raised to curb public debt and absorb rising social security costs. [ FULL STORY ]
New Corporate Tax Rules On Late Interest Payments Proposed In UK,
by Robert Lee, Tax-News.com, London
Wednesday, July 30, 2008
The UK tax authority, HM Revenue and Customs, has issued a consultation on proposed changes to the laws relating to the deduction of interest on late payments between connected companies, in the light of recent judgments by the European Court of Justice (ECJ). [ FULL STORY ]
Australian Government Lauches Consultation On Fringe Benefits Tax,
by Mary Swire, Tax-News.com, Hong Kong
Wednesday, July 30, 2008
Australian Assistant Treasurer Chris Bowen, has announced the launch of a consultation by the federal government into certain aspects of new Fringe Benefits Tax rules. [ FULL STORY ]

Onshore

Greece

Generally speaking, Greece is not an attractive location for individuals or companies seeking to limit taxation; the mainstream corporate income tax rate used to be 35%, although it was reduced in stages to 32% in 2005, 29% in 2006 and 25% in 2007. There are however some particular features of the Greek tax system which are attractive for certain individuals or companies in certain situations.

A new, general-purpose development incentive law was promoted by the government in 2005 and was received very warmly by the business community. In the first ten months of its implementation (end of March 2005 till the end of January 2006) 1,234 applications were submitted accounting for €2.47bn.

The law offers a combination of incentives and corporate tax breaks and is aimed at sectors of the economy that are open to international competition, such as tourism, information technology, financial services, and quality agricultural exports.

Learn more in our full Greece Knowledgebase.

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Directory

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Our aim is to offer you the ability to locate a service provider specialising in the field of your choice, in the jurisdiction of your choice, with just a few clicks. We only list confirmed entries to reduce the number of dead-ends and strictly enforce categorisation criteria to ensure that you find exactly the service you are after. As of September 2007 we have begun to implement a new, expanded format to make the directory even more user friendly and comprehensive.

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For Service Providers

The Lowtax Offshore Service Provider's Directory offers firms the ability to highlight their services to one of the web's largest specialised tax, legal and offshore audiences. Our visitors include large numbers of corporates and HNWIs. Standard entry in the directory is free as long as your details are kept up to date. Premium entry options are available. Please contact diectory@lowtax.net for further details.

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Onshore

The Netherlands

Although the Netherlands has a sophisticated tax system with high tax rates some aspects of its fiscal system are extremely attractive and make it the ideal location in which to base international trading operations. Attractive fiscal incentives are further enhanced by a complex network of double taxation treaties (few of which contain any anti avoidance provisions) and by the existence of a procedure of advance tax rulings whereby the tax authorities who are autonomous and approachable can at short notice specify the fiscal consequences of certain business structures provided that material financial interests are involved and the propositions are reasonable.

The Dutch government announced in 2004 that it would cut the country's corporate tax rate to 31.5% in 2006 from 34.5%.

Presenting the last budget prior to the election on November 22, 2006, Holland's long-serving Finance Minister Gerrit Zalm stated that the government would continue to cut the rate of corporate income tax, which fell to 25.5% in 2007 from 29.1%, putting it below the European Union average. This represents a 5% cut in corporate tax since 2005.

In anticipation of confirmation of the Marks & Spencer ruling on cross-border loss relief by the European Court of Justice, the government proposed to allow relief for losses incurred in other EU Member States. In addition, participation rules would be relaxed by eliminating the nonportfolio and "subject to tax" requirements. For "passive" participations, a "sufficient" tax rate test (possibly 10%) would be introduced.

Ruling in December 2005, the ECJ stated that companies could offset losses incurred by foreign subsidiaries as long as there was no "real possibility" that these could be absorbed at the local level at the time the claim was made.

According to the ruling, M&S could therefore claim tax relief for losses outside its home market, with the proviso that loss-making subsidiaries were unable to claim tax relief in their country of establishment.

Learn more in our full The Netherlands Knowledgebase.