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Rajendra Nayak Ganesh Pai The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of Sheraton International inc. vs. DDIT [2007] 293 ITR (AT) 68 examined the taxability of a foreign company engaged in the business of providing various services related to hotels. The taxpayer (US Co), a company incorporated in the US, entered into agreements with an Indian company (I Co) for providing services in the nature of publicity, advertisement, sales and reservation of rooms in the hotels of the I Co. It also permitted the I Co to use its brand name and trade mark as incidental to the main services provided. The I Co made a composite payment to the US Co at a percentage of total room sales and not with reference to any particular service. The issue before the ITAT was the taxability of the fees received by US Co from the provision of such services to the I Co. The US Co was a resident of USA within the meaning of article 4 of the double taxation avoidance agreement between India and USA (the treaty) and was eligible for the treaty benefits.

Bill Maclagan Kevin Zimka On September 21 2007, Canada and the US signed a new protocol (the protocol) to the Canada-United States tax convention (the treaty).

A new bill to limit tax planning in Portugal seeks to catch a wider group than first intended. Rogério Fernandes Ferreira of PLMJ explains how it will operate

Bernard Sweet, director of corporate tax at Chiltern, points to a severe implications in the new chancellor's first Pre Budget Report

Qatar Businesses based in the Qatar Financial Centre (QFC) will pay 10% tax from April 30 next year. The QFC Authority has announced that there will be no tax payable in the first three years of operation of the centre.

By Catherine Snowdon, Americas reporter

Nélio Weiss Philippe Jeffrey Back in 2003, two of Brazil's leading exporting companies had challenged the constitutionality of the applicability of the Social Contribution on Net Profits (CSLL) on income derived from export transactions, based on the modification of article 149 of the Brazilian Constitution by Constitutional Amendment – CA n° 33/2001. In that year, two Brazilian courts of first instance ruled that the export income was not subject to CSLL. As a general rule, Brazilian taxpayers are subject to a corporate income tax rate of 15%, plus income surtax of 10% on annual taxable income exceeding BRL 240,000, and also to CSLL, at the rate of 9% (usually referred as the combined 34% corporate tax rate).

Neil Wilson On July 17 2007, Prime Minister John Howard announced that a 'cap and trade' emissions trading scheme will be introduced in Australia which will assist Australia to substantially lower domestic greenhouse gases. This announcement was made following the release of a report by the joint government–business Task Group on Emissions Trading on June 1 2007 which outlined, amongst other matters, a proposed Australian domestic emissions trading scheme that should be based on a 'cap and trade' model. This model would result in a cap being set by the government to limit the greenhouse gas emissions of regulated organisations.

Deloitte and Skadden Arps Slate Meagher & Flom were the big winners at International Tax Review's second annual Americas Tax Awards. Deloitte was named the Latin America Tax Firm of the Year, while Skadden Arps took the trophy for the best tax firm in North America

Our cover story this month examines the vexed question of flat taxes. The merits and demerits of the arguments are set out clearly in a well argued piece by Catherine Snowdon. Emerging states have clearly benefited from the coherence and simplicity of the system though economists across the world are less convinced of its benefits for more complex economies.