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  • International plans to impose new taxes on financial institutions have failed to win widespread approval. Erin Kelechava and Salman Shaheen report that while some commentators accept the principle of levies for organisations that received government support during recent financial turmoil, they foresee problems in implementing the new charges
  • Nélio Weiss Philippe Jeffrey On December 16 2009, Brazil's executive branch published Provisional Measure (PM) 472 which, among other provisions, introduces thin capitalization rules. Although the PM 472 has entered into force as of December 16 2009, the Brazilian Congress initially had 60 days to veto the provision, modify it, or convert it into law. As the Congress did not act within this initial 60-day period, the PM has been extended for an additional 60-day period.
  • Nike De Bruyn Herman Driessen In the context of the new VAT rules, applicable from 2010 (the so-called VAT package), the Belgian VAT administration published a new Royal decree (RD n° 57) on March 25 2010 about the place of supply of freight transport services (and ancillary services), which are physically performed outside the EU (for example, a transport of goods from the US to Norway). The aim of this Royal decree is to delocalise the freight transport services, which are performed in a business-to-business (B2B) context, outside the EU if the actual use or exploitation took place in a non-EU country. As a result of this new provision EU VAT no longer applies.
  • Jeffrey Shafer The recent case TD Securities (USA) LLC v HMQ calls into question the Canada Revenue Agency's (CRA) view that a fiscally transparent US LLC is not a "resident" of the US under the Canada-US Income Tax Convention 1980 (the Treaty).
  • Following last month's Asia Tax Executives' Forum in Singapore, Ralph Cunningham and Jack Grocott discover what is really keeping Asia-Pacific taxpayers up at night. Increased scrutiny and dispute litigation rather than resolution really is the stuff of nightmares for the region's tax community.
  • Peter Dachs The Draft Taxation Laws Amendment Bill has been released for public comment. The Bill proposes various effective dates for the amendments contained in it. Some of the highlights for cross-border transactions in the Bill are as follows.
  • Vladimir Kotenko On April 30 2010 the Law on the State Budget 2010 took effect.
  • Kalina Figurska-Rudnicka In a judgment on April 13 2010 the Polish Supreme Administrative Court has confirmed a taxpayer's right to decrease their taxable amount by post-transaction rebates granted not to the purchaser of the goods but to the final customers. The case in question refers to rebates granted by a pharmaceutical company directly to pharmacies, leaving out wholesalers.
  • With the introduction of the CRC Energy Efficiency Scheme in the UK, and a carbon market in the EU that is worth more than $20 billion annually, Michael Cashman and Michael Hutchinson of Mayer Brown believe that understanding how the carbon trading market operates and the tax implications for the companies that participate in the market is becoming increasingly important.
  • Sophie Stylianou Orestis Livadas Cyprus today is considered as an ideal centre for the establishment of ship owning and ship management companies, mainly because of its strategic geographical position and good infrastructure. It is ranked among the top 10 most competitive shipping centres worldwide in terms of cost. It has one of the largest maritime industries and it is the biggest third-party ship management centre in the EU. Despite the need to preserve the favourable merchant shipping regime under Cypriot legislation, the need for the revision of the law arose to comply with the EU's guidelines on state aid to maritime transports.