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Neil Wilson A potential change in the view of the Australian Taxation Office (ATO) has cast uncertainty on the GST treatment of transactions made as part of property development arrangements, particularly those transactions between the Government and private sector. It would appear that this new approach will be applied by the ATO to both past and future interpretations of the GST law. Specifically, in respect of the past, it is understood that existing private rulings may be revoked and replaced with new rulings incorporating the new approach. Some developers will be protected by these private rulings, but some will not, depending on the circumstances.

Michael Friedman, Todd Miller and John Galambos at McMillan Binch Mendelsohn examine proposed tax reforms in Canada

Norton Rose has announced that Stephane Salou is to join its Paris office as a tax partner. Salou came from Orrick where he was a partner and head of corporate tax. At Norton Rose he will work with partner Laurence Toxe.

The Gulf state of Qatar is planning to cut its corporate tax rate to 12%. It stands presently at 35%. This is partly a move to rationalise the tax system while, at the same time, providing a low tax destination for corporates.

Massimo Agostini Preliminary ruling no. 80/E, dated April 26 2007 (the ruling) has addressed the Italian tax treatment of the income produced by an Italian branch of a law firm organised as a UK Limited Liability Partnership (LLP). The ruling also looked at how income is attributed to the LLP's Italian partner is to be taxed.

Rajendra Nayak Ganesh Pai The Mumbai income tax appellate tribunal (ITAT) recently examined the taxability of a foreign enterprise having a permanent establishment (PE) in India on account of a dependent agent (DA). The taxpayer, a resident of and incorporated in Singapore, was engaged in the business of broadcasting and uplinking television channels. It had appointed an Indian company (the company) as an agent to market ad-space on its behalf, for a commission on an arm's length basis. The taxpayer had a PE in India under the tax treaty between India and Singapore (tax treaty), by virtue of the company being regarded as a DA carrying out certain activities on behalf of the taxpayer. The issue before the ITAT was whether in view of the taxpayer having remunerated the company on an arm's length basis, any further income should be taxed in India, other than the profits earned by the company.

Volker Jorczyk Travel agents selling airline tickets do not charge VAT on their commission received from the airline, but must do so if they are acting for the customer. However, only the commission on the domestic portion of a flight is chargeable. Traditionally, travel agents´ commission has been VAT-free irrespective of the method of settlement. Lately, though, more and more airlines are refusing to remunerate the travel trade, preferring to deal with passengers online. This leaves the agent with no option but to raise a service charge on the customer, subject to VAT for the distance flown in German airspace. The finance ministry tried to simplify matters with a decree in March 2006 arbitrarily declaring a flight within the EU to be 25% flown in Germany, falling to 5% on flights to destinations elsewhere.

A European Commission decision has forced Luxembourg to change its holding companies legislation, reports Keith O'Donnell and Samantha Nonnenkamp of ATOZ Tax Advisers

Life at the top of any industry is tough and that is certainly true of in-house tax departments. Here, the ten most admired tax directors in Europe, as voted for by International Tax Review readers, tell Catherine Snowdon about the issues they face and how they deal with the pressures of their jobs.

Massimo Agostini of Gianni Origoni Grippo & Partners has created a hypothetical company to demonstrate the tax treatment of Italian holding companies and their shareholders