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  • 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.
  • Gagnon Jean On November 13, 2007, the Department of Finance tabled a Notice of Ways and means motion to implement proposed amendments to the Income Tax Act partly in response to fiscal policies previously anno-unced. The amendments include the following measures:
  • 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.
  • Yongjun Peter Ni and Gilbert Ng of Ernst & Young predict the scope of the regulations which implement China's new Enterprise Income Tax Law
  • Todd Miller and Michael Friedman of McMillan Binch Mendelsohn in Toronto explain why the new protocol to the treaty offers both significant tax benefits and new challenges
  • The Isle of Man has adopted a zero-10 tax regime. Jersey and Guernsey are about to do so. KPMG's Tony Mancini in Guernsey, John Riva in Jersey and Greg Jones in the Isle of Man compare the three systems
  • Indian parliament: getting ready to look at APA rules Tax authority officials in India have bowed to business pressure and begun a process towards the adoption of advance pricing agreements (APAs).
  • Hong Kong: reaching out A new double tax treaty has been concluded between Hong Kong and Luxembourg. It is Hong Kong's fourth in recent years. It signed similar deals with Belgium in 2003, Thailand in 2005 and mainland China in 2006.