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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.

Sharon Shulman Motti Tagar Leverage structures are frequently used worldwide in the acquisitions of companies. In general, the attempt of leverage is to maximise the utilisation of the borrowed money in order to increase the return on the investment to the investors. One of the main tax advantages of leverage structures is that they could erode the tax base in the target's jurisdiction by the deduction (as much as possible) of interest expenses associated with the debt used for the acquisition against the profits of target.

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.

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.

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

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

Bermuda and the UK have signed a tax information exchange agreement. It is the third such deal for Bermuda but the first for the UK. It means that both countries will be able to obtain tax information from the other regardless of a crime having been committed.

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.