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  • Thomas Pippos On February 4 the new National led centre right government announced a number of initiatives to help stimulate economic activity.
  • Roberto del Toro Mario Alberto Gutierrez The provisions of the Iceland-Mexico income tax treaty, which was signed in Mexico City on March 11 2008, apply from January 1 2009. Mexico's official gazette on December 11 published the Mexican Senate's authorisations of Mexico's tax treaty with Iceland and the text of the treaty itself on December 31 2008. The treaty not only covers the Mexican income tax, but also, the new Mexican flat tax (IETU). Some of the main provisions included in the treaty are:
  • By Jack Grocott
  • Firms that are adapting better to the changed economic circumstances, are showing their worth in International Tax Review's second annual poll to find the leading transactional firms around the world
  • Janne Juusela As a result of the recent ECJ case law (C-170/05, Denkavit and C-379/05, Amurta) the Finnish government issued a bill (HE 113/2008) on November 12 2008 amending the act on the taxation of non-residents' income (627/1978). According to the bill, taxation of Finnish source dividends paid to non-residents were to be amended to correspond to the taxation of dividends paid to residents to conform to EC Law. The parliament passed the bill on December 5 2008 and the changes entered into force from January 1 2009.
  • Guillaume Glon Nicolas Jacquot On January 13 2009, the US and France signed a protocol making significant changes to the existing tax treaty, especially as regards certain dividends, royalties and the limitation on benefits (LoB) clause.
  • Luke Mlynarczyk Jeffrey Shafer Recently, the Federal Court of Appeal unanimously upheld the Federal Court's decision in eBay Canada Limited and eBay CS Vancouver Inc. v MNR.
  • Nélio Weiss Philippe Jeffrey For a fourth consecutive year and with the objective to minimise the effect for Brazilian exporting companies from the appreciation of the local currency in relation to foreign currencies (specifically the US dollar and the Euro and mainly during the first semester of 2008), the Brazilian authorities issued on December 29 2008, ordinance 310 and normative instruction 898 which amended the Brazilian transfer pricing legislation. The ordinance and normative instruction state that Brazilian exporting companies will be allowed to increase their export revenues for calendar year 2008 (for transfer pricing calculation purposes) using the ratio of 1:20. This measure will apply for the fiscal year 2008.
  • By Catherine Snowdon
  • Clemens Hasenauer Johannes Prinz The Austrian ministry of finance has recently published new investment fund guidelines (Investmentfondsrichtlinien 2008). The new guidelines also deal with various aspects of the Austrian tax treatment of foreign investment funds including the criteria for the classification as foreign fund and its eligibility for tax treaty benefits.