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Jordi Domínguez As mentioned in our previous contribution to the International Tax Review, late in July the government released a first draft of new regulations. Its purpose is (i) developing law 36/2006 on measures for the prevention of tax fraud, and (ii) also amending the corporate income tax regulations.

Peter Dachs The Supreme Court of Appeal has made a rare judgment on a permanent establishment issue. The appellant in the case qualified as a resident of South Africa and was a partner in a law firm in Lesotho.

Sharon Shulman Motti Tagar In our previous article, we discussed the ability of Israeli technology companies to enjoy certain tax incentives in Israel. This article will discuss the Israeli tax treatment of capital gains and dividend, as another consideration in structuring an acquisition of an Israeli technology company.

By Catherine Snowdon, Americas reporter

By Henry An, Won-Yeob Chon, Heui-Tae Lee and Joon Yang of Samil PricewaterhouseCoopers

By Harvey Mayne of PricewaterhouseCoopers

S Madhavan, of PricewaterhouseCoopers, India, examines the complexity of indirect taxes in India

Sophie Stylianou Until recently, it was obligatory that contracts with a consideration of up to CYP 100,000 ($237,473) were subject to a stamp duty of 0.15%, while any amount in excess of CYP 100,000 was subject to a stamp duty of 0.2%.

Paul Stepak When a Canadian subsidiary of a multinational business borrows money from third parties, the borrowing is often guaranteed by a foreign parent (or another affiliate). Certainly there are good commercial reasons why such guarantees are provided, namely to improve the credit quality of the indebtedness thereby reducing the third-party financing costs for the Canadian subsidiary. It seems reasonable to expect that the parent might charge a guarantee fee in such circumstances and that under the domestic transfer pricing rules in the parent's jurisdiction such a fee (set at arm's length terms) might be required (or deemed to be paid).

Andrés Edelstein Ignacio Rodríguez After Congress approval, on August 10 2007 the Argentine Executive Branch has enacted an amendment protocol signed six years ago between Argentina and France to their 1979 double tax treaty (Law 26,276).