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Bob van der Made On May 2007, the European Commission issued a communication on the progress made on the Common Consolidated Corporate Tax Base (CCCTB) which also includes an outline of the work still to be done. The European Commission remains committed to presenting a legislative proposal in 2008.

Stephen Nelson The PRC State Administration of Taxation issued a notice on April 4 2007 (Guoshui (2007) 403) interpreting the Hong Kong-China double tax arrangement (DTA) The notice is of relevance not just to Hong Kong tax residents, because it also is applicable to other tax treaties if the relevant issues are identical and no prior interpretation has been issued. There are many aspects in the notice that deserve attention but for the present discussion, we will focus on permanent establishment (PE).

Ricardo Zúñiga In concord with a trend of tax reform during the last months, the governments of the Central American countries have adopted or are discussing new legislation as part of an implementation programme provided for by the Free Trade Agreement between Dominican Republic, Central America and the United States of America (DR-CAFTA). New tax legislation is under discussion to comply with a preparatory schedule of regional reforms prior to engage in trade negotiations with the EU. This agreement with the EU would also include Dominican Republic and Panama as signatory countries. Other pieces of legislation would be issued with the purpose to facilitate compliance with domestic tax obligations and formal duties.

Bill Maclagan Kevin Zimka The Canadian government introduced its 2007 Budget on March 19 2007 (the budget), and dealt with a series of items in the international tax area, including matters relating to the Canada-United States Tax Convention (1980)(the Treaty). In the Budget the government announced that it was close to finalising a new protocol to the Treaty (Protocol).

Nélio Weiss Philippe Jeffrey On May 25 2007 the tax authorities issued normative instruction (NI) 744 which set forth specific conditions that need to be fulfilled to allow Brazilian entities to claim a 0% withholding income tax rate on remittances to a foreign entity for promotion, publicity and market research expenses and leasing or rental of stands or space relating to the promotion of Brazilian products.

By Jose Casas (Mexico), Marcelo Castillo (Argentina), Manuel Del Rio (Peru), Matthias Kaut (Germany) and Eduard Sporken (The Netherlands)

Rafal Mikulski Polish restrictions on input VAT on passenger cars violate the European Union's sixth directive. The Administrative Court (First Instance) in Wroclaw, Poland, on April 4 2007 has issued a precedential verdict in which it has decided that Polish restrictions on the input VAT deductions on purchase, import and lease of passenger cars violates the Sixth Directive standstill regulations.

By Brian Cody (US), Tony Gorgas (Australia), Alexander Loh (Germany) and Ron Simkover (Canada)

By Gianni De Robertis (Italy), Sean Foley (US), Jaap Reyneveld (The Netherlands), Sergio Schuindt (Brazil) and Tomoko Wada (Japan)

By Jan Martens (France), John Neighbour (UK), Damian Preshaw (Australia) and Robin Saunders (UK)