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Emmanuel Picq The French Finance Act for 2008, approved on December 18 2007, includes various measures intended to boost innovation and productivity, including a substantial enhancement of the R&D credit system.

Rajendra Nayak Ganesh Pai In two recent rulings, the Delhi Income-tax Appellate Tribunal (ITAT) has ruled on the question of PE and income attribution to the PE. The rulings are in the case of Rolls Royce Plc vs. DIT which involved the India-UK tax treaty and Galileo International Inc vs. DDIT which involved the India-USA tax treaty. The Rolls Royce ruling relates to the case of a UK company – Rolls Royce (RRPLC) – which was engaged in supplying aero engines to Indian customers. Rolls Royce India Limited (RRIL), a UK subsidiary of RRPLC, had an office in India which was engaged in providing support services to RRPLC.

Sophie Stylianou The Cyprus Companies Law, Cap. 113, was recently amended, to incorporate new significant provisions with regard to the preparation of consolidated financial statements by small sized groups.

Clemens Hasenauer Johannes Prinz Recent legislation entering into force in 2008 (Abgab-ensicherungsgesetz 2007, Mittel-standsfinanzie-rungsgesellschaften-Gesetz 2007) has introduced several changes in Austrian (corporate) income tax law.

Britain's tax authorities have changed how transfer pricing enquiries are dealt with in the UK. HM Revenue and Customs signalled the new plans in October last year when it published the Making a difference: clarity and certainty document after a public consultation. Now it has announced what these plans will mean.

Jose Maria Cusi of Clifford Chance warns that new rules have made Spain's transfer pricing regime much tougher following significant amendments to corporate income tax

Bob Reynolds argues that tax intermediaries report could face implementation difficulties after calling for greater co-operation between advisers, authorise and taxpayers

By Joanna Faith

Brazil's federal government is introducing tougher rules on ethanol producers for the PIS/Cofins social security tax.

Norway parliament New transfer pricing documentation rules have been introduced in Norway. Although the law introducing the changes was agreed by the parliament in Oslo in June, the implementing rules were finalised only as the year came to an end.