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By Alexei Matveev and Anna Ryzhkova, Ernst & Young, Moscow

Free movement of capital – Profits distributed to a parent company exempt from withholding tax in the member state of the subsidiary – Concept of ‘company of a member state’ – ‘Societe par actions simplifiee’ under French law.

By Daniel Keller, Christian Schubert and Diana-Catharina Kurtz, PricewaterhouseCoopers, Germany

The recession has helped thrust indirect taxes into the spotlight. Often referred to as invisible taxes, indirect taxes are now a focal point for tax authorities seeking to claw back much needed revenue. As company profits remain low, Treasuries can no longer rely on direct tax revenue to plug expanding deficit holes. As a result indirect taxes have reached the attention of not just tax directors but chief financial officers and senior management. Once, they were just considered a compliance issue, now taxpayers realise the benefits of well managed indirect tax processes. In struggling economic times, how much a taxpayer owes to various revenue authorities becomes critical. The usual concerns surrounding transactions and inventive planning take a back seat. Though many countries may technically be coming out of recession, the after effects of the worst economic crisis since the Second World War will be felt for a long time to come. Well-managed indirect tax processes will help weather the storm but also put companies is a better position for the future.

Taxpayers have some time to plan for changes to the check-the-box rules, which will affect income deferral. But don't leave it too late, says James Wall of Nexia International member firm JH Cohn

The report of the Irish commission on taxation may not be acted upon immediately, but it still produced some worthwhile pro-business recommendations says Olivia Lynch, president of the Irish Taxation Institute

Dirk Van Stappen On February 12 2009 the Court of Justice of the European Communities (CJEC) ruled in the Cobelfret case that the Belgian regime of the dividends received deduction (DRD) does not implement the parent-subsidiary directive correctly.

Commenting on behalf of the Tax Council Policy Institute, Tobin Treichel and Elizabeth Coffin of United Technologies Corporation believe that US business tax reform must give US enterprises a balanced opportunity to compete effectively around the world

Gerry Thornton Lynn Cramer Ireland has recently signed a double tax treaty with the Republic of Moldova. The treaty substan-tially follows the OECD model convention in dealing with issues such as residence, permanent establishment and exchange of information. In general, the treaty applies to Irish income tax, corporation tax and capital gains tax and Moldovan income tax.

Ron Richler Edward Miller The fifth protocol to the Canada-US income tax convention introduced rules relating to hybrid entities. One of the new rules will apply to payments made by Canadian unlimited liability companies (ULCs) effective January 1 2010.