Tax:

Practical European Tax Strategies

WorldTrade Executive Inc.
Newsletter  12 issues per annum

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Practical
The Authoritative Guide to Reducing Tax Liability in European Transactions

European taxation is increasing complex, but of critical importance to your bottom line. Do you have access to the innovative solutions, strategies and "best practices" you need to succeed?

Practical European Tax Strategies
will show you, in clear and practical terms, how the world's most successful companies are managing their international tax liabilities.

Coverage includes:
  • Tax implications of Pan-European cash pooling.
  • Avoiding VAT pitfalls in cross-border services and contract manufacturing.
  • Use of "Multi-dip" structures and other devices which rely on cross-border tax asymmetries to generate tax savings.
  • How to take advantage of competition between EU member states to provide attractive tax regimes.
  • Tax planning for the cross-border grouping of companies.
  • Managing or avoiding transfer tax liability.
  • Tax planning to minimize expatriate taxes.
  • How to structure your European manufacturing or sales operation in order to minimize your tax burden.
  • Managing VAT recovery procedures to reduce cash flow drain.
  • The impact of the Euro on tax reporting and accounting issues.

Each issue of Practical European Tax Strategies provides commentary and advice illustrated by case studies of major corporations along with feature articles by senior practitioners at leading law and accounting firms. You will notice a practical, action-oriented presentation incorporating a hands-on perspective

European Tax Advisory Board:

    Richard E. Andersen, Esq., Arnold & Porter
    Sunghak Baik, Esq., Ernst & Young
    William C. Benjamin, Esq., Hale and Dorr
    John I. Forry, Esq., Ernst & Young
    Jaime Gonzalez-Bendikson, Esq., Baker & McKenzie
    Howard M. Liebman, Esq., Jones, Day, Reavis & Pogue (Brussels)
    Keith Martin, Esq., Chadbourne & Parke
    Antoine Paszkiewicz, Esq., Kramer, Levin, Naftalis & Frankel (Paris)
    Cristian Rosso Alba, Esq., Hope, Duggan & Silva (Buenos Aires)
    Eric Tomsett, Deloitte & Touche (London)

    Miguel Valdes, Esq., Ernst & Young
    Michael A. View, Esq., Ernst & Young

    Publication:   Practical European Tax Strategies
    ET0304  March 31, 2004
    ET0304   (requires Adobe Acrobat Reader)
    Summary:  
    Legislative Developments
    This issue begins with an article on new tax planning opportunities
    arising from the Irish Finance Bill, including, for example, an
    expanded R&D tax credit and the prospect of the "onshore pooling" of
    tax credits in certain cases. Page 1.
    Securitizations
    Luxembourg's legal, regulatory, and tax environment has made it an
    appealing location in Europe for financial groups. We examine the
    emergence and tax treatment of a new product there -- synthetic
    securitizations. Page 1.
    Treasury Practice
    Our Planning Advisory looks at transfer pricing issues in the UK
    involving intra-group financing, guarantee fees, and treasury services.
    The emphasis is on what corporate treasurers need to know to manage
    these issues. Page 3.
    Transfer Pricing
    In a second article about transfer pricing issues, Practical Strategies
    brings you a quick summary of recent changes in Poland's transfer
    pricing regime. Page 7.
    Country Focus
    Tax developments in Poland make it a focus in this issue, with an
    article on changes in the country's thin capitalization rules. The
    rules have been broadened to cover interest paid on bonds issued by a
    company to its parent and/or sister companies. Page 12.
    Real Property
    A tax on offshore companies owning real estate in Portugal has begun to
    have an impact, raising costs for foreign property holders there. This
    article explores one option for avoiding the problem --
    "redomiciliation" in Malta. Page 13.
    Snapshots
    Pages 8, 9, 11 & 14.
    
    





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