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ARTICLES
Austria
Group Taxation Regime: A Landmark Model
Robert Schneider
pp. 118-128
The Austrian 2005 Tax Reform, which became effective on 1 January 2005, had a dramatic impact on the corporate tax system. The new group taxation regime has been acknowledged as one of the most competitive regimes in the world due to its flexibility and cross-border tax relief granted for losses incurred by foreign subsidiaries. This article highlights the details of the new system.
International
Taxing Speculation in Financial Markets: A Comparison between the United Kingdom and Australian Common Law and Tax Rulings
Tony Ciro
pp. 129-138
This article examines the recent tax ruling issued by the Australian Tax Office (ATO) involving contracts for differences. The law on gaming and wagering, and on futures markets in both the United Kingdom and Australia are also reviewed. A survey of the law is presented in the context of assessing whether contracts for financial derivatives and other similar operations amount to gaming transactions, which are largely exempt from Australian and UK income tax laws.
Slovakia
Tax Treatment of Financial Derivatives
Renata Krajcirova and Michaela Stachova
pp. 139-142
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COMPARATIVE SURVEY
Tax Treatment and Consequences of Debt Restructuring and Workouts
In a post-Enron world, many financing transactions have come under intense scrutiny from both regulators and shareholders, with the ensuing business climate concerned with achieving greater transparency and reliability of financial statements. Such transactions include debt restructuring and workouts. The present comparative survey intends to provide a comprehensive overview of the tax consequences of these transactions according to the domestic legislations of several jurisdictions.
Argentina
Sergio Caveggia, Carlos Aquila and A. Gustavo Consoli
pp. 143-150
Brazil
Gustavo Lian Haddad, Ricardo Ferreira Bolan and Antenori Trevisan Neto
pp. 151-157
RECENT DEVELOPMENTS
Italy
Implementation of the Interest and Royalties Directive
Paola Flora
pp. 158-164
Comprehensive article providing a thorough outline and a useful insight on the contents and terms of Italian implementation of the EU Interest and Royalties Directive.
CUMULATIVE INDEX
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