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Loss of tax receipts hits Zambia's poor Zambia's government has begun renegotiating fixed tax agreements held by international mining firms. It aims to have these operational by early in 2008.

A third round of public consultation on new international tax rules was announced by the New Zealand government at the beginning of December.

By Catherine Snowdon, Americas correspondent

Neil Wilson Legislation to implement the third and fourth stages of the Taxation of Financial Arrangements (TOFA) reforms was introduced into parliament on September 20 2007 as the Tax Laws Amendment (Taxation of Financial Arrangements) Bill 2007.

Rajendra Nayak Ganesh Pai The Mumbai bench of the income tax appellate tribunal (ITAT) in the case of Bharat Petroleum Corporation Ltd vs JCIT (2007) 111 TTJ (Jd) 375 examined the taxability of fees paid to a non-resident for conducting a market study. The taxpayer is a company incorporated in India and is engaged in the business of refining crude oil and marketing petroleum products. The taxpayer appointed a consultant for conducting a market study which covered among other things; supply and demand analysis and price forecast. The market study was an update of an earlier market study undertaken by the consultant for the taxpayer. The issue before the ITAT was the taxability of the fees paid by the taxpayer to the consultant for the update of the market study. India has entered into a double taxation avoidance agreement with Singapore (treaty). The consultant was a resident of Singapore within the meaning of article 4 of the treaty and was therefore eligible for the benefits.

Dieter Endres The Supreme Tax Court has upheld the principle that fees paid to a foreign provider must be paid under deduction of any withholding tax required by domestic law, unless the payer is in possession of an official exemption certificate from the Central Tax Office in Bonn.

Bob van der Made The European Commission has issued its latest progress report on the common consolidated corporate tax base (CCCTB working paper 57 entitled: Possible elements of a technical outline). The document was discussed by the Commission and the EU's member states at the end of September during the CCCTB working group meeting. EU tax commissioner Kovacs has recently announced that a directive on the CCCTB will be proposed by the Commission to ECOFIN in September 2008 under the French presidency of the EU.

Daren Yeoh, tax partner of Moore Stephens in Australia, in the second of a two-part series, looks at the methodologies for calculating taxable gains and loses