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Nélio B. Weiss Philippe Jeffrey A Brazilian court of first instance from the State of Espírito Santo recently issued an important decision in connection with the non-application of withholding income tax on remittance for services to a beneficiary located in a tax treaty country. The court ruled out that remittance for technical service (not involving a transfer of technology or know-how) to a resident of Finland could not be subject to the 15% Brazilian withholding income tax due to the application of the article 7 (business profits) included in the Brazil-Finland tax treaty.

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

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

The OECD's member states are to begin accession talks with Chile, Estonia, Israel, Russia and Slovenia. The Organisation will also "engage more closely" with other economies, for example, Brazil, China, India, Indonesia and South Africa.

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

Yongjun Peter Ni and Gilbert Ng of Ernst & Young predict the scope of the regulations which implement China's new Enterprise Income Tax Law

Roberto del Toro José Antonio González Mexico continues its efforts to improve the commercial relationship with other countries through the negotiation of tax treaties for the avoidance of double taxation.

Henry An David Jin-Young Lee On October 2 2007, the Ministry of Finance and Economy (MOFE) announced its draft bill to revise the Special Tax Treatment Control Law which includes the new provision on partnership taxation as part of the 2008 tax reform. If the bill is approved by the National Assembly, the partnership rules will become effective for fiscal years beginning on or after January 1, 2009. A brief summary of the key items proposed by MOFE are:

Lorenz Bernhardt and Claudia Kühnlein of PricewaterhouseCoopers discuss the transfer pricing implications of German tax reforms