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Akio Takisaki In June of 2005, the Japanese legislature enacted new legislation abolishing the Yugen Kaisha (YK) limited liability entity and creating several new entities, including the Godo Kaisha (GDK), a new limited liability entity. The new Corporate Law became effective on May 1 2006.

Rajendra Nayak Ganesh Pai The Mumbai Income Tax Appellate Tribunal (ITAT) in the case of Van Oord Dredging & Marine Contractors BV vs. DDIT (Mumbai) 105 ITD 97 examined the taxability under the India-Netherlands tax treaty (the treaty), of an arbitration award. The tax payer was an international dredging contractor and a tax resident of the Netherlands. It executed contracts in India through project/site offices maintained in India. Subsequent to closure of its project/site offices in India, the taxpayer earned income pursuant to an arbitration award, in relation to a project that was completed in an earlier year. The issue before the ITAT was the taxability of such income considering that there was no permanent establishment (PE) of the taxpayer in the year of receipt of income.

Stephen Nelson Now that the new PRC Enterprise Income Tax Law has passed and will enter into effect next year, foreign investors should consider whether it is appropriate to restructure their investments in China to cope with the changes.

Among the initiatives of the Chilean government to foster investment contained in the Chile Invests project, the executive sent a bill to Congress with a special regime for accelerated depreciation. The project bill applies to those taxpayers subject to corporate tax (First Category Tax) and sets forth that if between March 1 2007 and December 31 2008 the taxpayer acquires new assets locally or import assets into the country, they will be able to deduct a depreciation quota equivalent to 50% of their net value in the year in which they start using them. The balance of 50% will be subject to the existing depreciation rules. In regard to this portion, taxpayers will have to opt between the linear and the ordinary accelerated depreciation regimes.

Neil Wilson On March 7 2007, the Australian Taxation Office (ATO) released Taxation Ruling TR 2007/1, "Income tax: international transfer pricing: the effects of determinations made under Division 13 of Part III of the Income Tax Assessment Act 1936, including consequential adjustments under section 136AF of that Act". TR 2007/1 had not previously been released as a draft; however, this ruling replaces TR 1999/8 (which has been actively withdrawn as of March 7 2007). TR 2007/1 applies retrospectively.

Doug Richardson Kurtis Bond The 2007 Canadian federal budget (the Budget) was released by the minority Canadian Conservative government on March 19 2007 and was passed in the House of Commons on March 27 2007.

The European Court of Justice looked at two separate UK cases in much the same way, believes Simon Whitehead of Dorsey & Whitney

Elzbieta Serwinska Recently the Polish tax courts (Regional Administrative Courts) have issued verdicts on refunds of Polish VAT to foreign entrepreneurs, which may significantly increase the chances of other applicants to obtain the refund.

Peter Dachs South Africa's recent Budget contained a number of surprising and far reaching amendments.

Stefan Ditsch Barbara Zuber From 2007 onwards, the statutory requirements for treaty relief from German withholding taxes on payments to foreign companies have been significantly tightened. Withholding tax rate reductions will not be granted on payments to a foreign company to the extent its own shareholders would not have been entitled to the relief, had they received the income direct, unless: