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In the past decade South Africa has introduced a series of amnesties to catch tax evaders. Beric Croome, of Edward Nathan Sonnenbergs, examines the policy's success

Andrés Edelstein Ignacio Rodríguez Argentina non-residents are subject to income tax exclusively on their Argentine-source income. Pursuant to this rule, the non-resident pays tax through a 35% withholding tax levied on a deemed net income equivalent to a percentage of the gross payment received. Unless provided otherwise in the income tax law, 90% of the gross revenue derived by the non-resident from Argentine source is deemed taxable net income, which gives rise to an effective 31.5% withholding tax.

Tax executives and advisers came from all over Asia to attend the second annual International Tax Review Asia Tax Awards in Hong Kong in November

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.

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:

Bob Reynolds talks to Dave Hartnett, acting chairman of HMRC, about openness and dialogue with international businesses

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.

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