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  • Carl Pihlgren Mika Persson The Swedish parliament has issued a final bill about cross-border tax consolidation. New rules related to investment funds have also been proposed.
  • Rajendra Nayak Ganesh Pai The Mumbai Income Tax Appellate Tribunal in the case of Valentine Maritime Mauritius [2010-TIOL-195-ITAT-MUM] ruled on the taxability of certain contracts executed in India under the India-Mauritius tax treaty. The taxpayer is a company incorporated in Mauritius and is engaged in the business of marine and general engineering and construction. During the relevant tax year, the taxpayer executed three contracts in India: (1) Replacement of a deck; (2) Charter of a barge (for accommodation purposes); (3) Charter of a barge along with the provision of technical personnel. Under the treaty, a permanent establishment (PE) includes a building site or construction or assembly project or supervisory activities in connection therewith where such site, project or supervisory activities continue for a period of more than nine months (construction PE rule). While each of the contracts taken individually lasted for a period of less than nine months, the aggregate time spent on all the contracts put together exceeded the nine months time threshold. The main issue before the tribunal was whether the taxpayer has a PE under the construction PE rule of the treaty.
  • Elena Kostovska The small and open economy of FYR Macedonia continues to take steps towards attracting foreign direct investment with legislative changes that equalise conditions for foreign and domestic investors as well as with extensive investment incentives.
  • Stephen Dale Arnaud Moraine The French real estate VAT regime changed fundamentally from March 11 2010. The objectives of the French government in amending the VAT regime, applicable to Real Estate, are:
  • A booming economy and an increasing focus on investment is forcing the Indian tax authorities to step up scrutiny on all cross border trade. Rohan Phatarphekar and Hardev Singh of KPMG outline how transfer pricing will be the hot topic over the coming year.
  • A complete re-write of the country's 1961 income tax law, a goods and service tax, a new advance pricing agreement programme, a growing litigation problem and a heightening risk of audits means the next year in India will be one of the busiest ever. Jack Grocott investigates.
  • Taxpayers should expect significant changes when the second draft of the release of the India's new direct tax code is released later this month, say leading tax professionals.
  • The South African government has released a draft Bill for public comment, including changes to the country's participation exemptions on foreign dividends and VAT provisions.
  • The Australian government is taking a gamble with tax at the same time as it was criticised for its timid response to a review of the tax system led by the secretary of its own Treasury department.
  • Edward Tanenbaum Tola Ozim On March 17 2010, the House Ways & Means Committee approved The Small Business and Infrastructure Jobs Tax Act of 2010 (HR 4849), which is effective upon enactment and, among other things, limits tax treaty benefits for multinational firms based in third-party countries. Representative, Sander Levin (democrat-Michigan) sponsored the Bill, which seeks to strengthen the American economy, assist small businesses and create jobs.