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Emmanuel Picq

Elena Kostovska One of the laws amended in September was the Corporate Income Tax (Profit Tax) Law. The amended law was published in the Official Gazette on October 3 2011 and came into force on October 11 2011.

Astrid Schudeck

Nélio Weiss, PwC

Sead Dado Salkovic, Eurofast Global Due to the adverse situation in the state budgets of many countries, the economic analysts and state officials are proposing different solutions to counteract the effects of the economic crisis.

Dieter Endres, PwC The anti-treaty (and anti-directive) shopping rule in force for the past few years refused treaty relief from withholding tax to foreign companies held by persons who would not have been entitled to the relief, had they received the income in their own names, if the arrangement was considered abusive. Abuse was assumed if either there was no business or other good reason for interposing the foreign company, or the foreign company earned no more than 10% of its gross income from its own business activity, or it did not maintain an appropriate establishment for its business activity. This rule has come in for criticism from various quarters, mostly because it can disqualify European holding company and other structures generally seen as fair and reasonable. Particularly this latter point prompted the European Commission to open infringement proceedings against Germany.

The Argentina Supreme Court of Justice has recently issued a significant decision that sheds light on a longstanding and highly debatable issue in the area of tax free reorganisations. Guillermo Teijeiro of Negri & Teijeiro Abogados analyses the conditions that need to be complied with when reorganisations take place within the same economic group.

Fighting the greenhouse effect has been a national priority for France for a long time. Sonia Bonnabry of Lexcom looks at how the country is reviving its plans for a carbon tax and learning from past mistakes.

The Internal Revenue Service (IRS) and US Treasury Department recently released proposed regulations clarifying the rules on tax accounting methods used by US shareholders for purposes of computing the earnings and profits of foreign corporations (REG-114749-09).

A collaborative approach from taxpayers and officials has seen a growth in the popularity of unilateral advance pricing arrangements in New Zealand, explain Mark Loveday and Tanmoy Chakrabarti of Ernst & Young.