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Samir Haouari Veerle Coussee In the framework of the 2008 budget discussions, the Belgian federal government has the intention to subject the sale of land in certain circumstances to VAT (21%). This implies a significant change in the current legislation, which foresees that the sale of land is under any circumstances exempt from VAT but subject to registration duties (10% or 12.5%, depending on the competent region). As the application of VAT in principle implies an exemption from registration duties, the regions will have to limit their scope of competence to impose registration duties on the sale of land.

Gaurav Taneja of Ernst & Young wonders when there will be an end to controversy about PEs and income attribution

Sweden is an interesting alternative to the more traditional holding company locations, say Carl Pihlgren and Sara Bolmstrand of Ernst & Young

Kevin Zimka Lisa Eastwood On September 21 2007, Canadian minister of finance Jim Flaherty and US secretary of the Treasury Henry Paulson signed the fifth protocol (the protocol) to the Canada-US Income Tax Convention (the treaty). The protocol amends the treaty to provide for Canada's first limitation on benefits (LOB) provision in any of its tax treaties. Previously the LOB provision in the treaty only applied to the application of the treaty by the US. The new LOB provision is intended to address perceived treaty shopping, by ensuring that Canadian residents can only obtain full benefits of the treaty where they meet the criteria to be a "qualifying person" (there are noted exceptions to this rule).

By Bob Reynolds

Berwin Leighton Paisner (BLP) has appointed Michael McKenna as partner in the firm's tax practice. McKenna joins from Goldman Sachs International where he was tax counsel advising on all aspects of their businesses and transactions outside of the USA.

With its wide tax treaty network, EU membership, and low taxes, Cyprus is a seductive prospect for international firms, says Paul Mallis of Deloitte

Turlough Galvin

Rahul Krishna Mitra, partner in PricewaterhouseCoopers India, says that the Indian tax authorities need to catch up with the rest of the world on transfer pricing

Welcome to the special feature on holding companies in the June issue of International Tax Review.