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News & Press

April 07
The New China "corporate income tax Law"
On 16 March 2007, China's legislature adopted the long-awaited corporate income tax reform. The new corporate income tax Law coming into effect on 1 January 2008 unifies the previously separate corporate income tax regimes for domestic enterprises and foreign-invested enterprises into a single tax r (...)

April 07
New China "corporate income tax law" : Implications and recommendations for Swiss Investors
The new corproate income tax law ("CIT Law") brings a fundamental change in China’s tax policy towards foreign investors. Existing Swiss investors should review their tax profile, conduct impact analyses and revisit their current tax-planning structures for their China business. For investment (...)

mars 2007
France: More Favourable Guidelines on CFC Rules
The French tax administration recently published detailed guidelines on the new CFC rules entered into force on 1 January 2006. The Main Clarifications in Brief Qualifying participation: To determine the level of participation, the rights held directly and those held indirectly must be added togethe (...)

mars 2007
China: Corporate Tax Reform Passes Legislature
National People's Congress Approves New Corporate Income Tax LawMarch 2007 : China's legislature held its final vote on the long-awaited tax reform and approved the new Corporate Income Tax Law ("CIT Law"). Heavily influenced by the current 5-Year Plan's theme of building a harmonious society, the n (...)

mars 2007
Implementation of the EU Interest and Royalties Directive
In 2005 Italy implemented the EU Interest and Royalties Directive with Legislative Decree No. 143/2005 restricting its scope of application to interest and royalty payments accrued (i.e. having become payable) on or after 1 January 2004 with the aim to prevent fraud and tax evasion by intentionally (...)

14 septembre 2006
The ECJ finds UK CFC Rules in breach of the EU Freedom of Establishment
On 12 September 2006, the European Court of Justice (ECJ) released its judgment on the Cadbury Schweppes case (C-196/04). The ECJ found that the UK Controlled Foreign Company (CFC) rules, which apply when a foreign subsidiary of a UK parent is subject to tax at a remarkably lower level than the corr (...)

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