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By Alvaro Taiar, Alcides Mariano and Ana Luiza Salles Lourenço of PricewaterhouseCoopers Brazil

Edward Tanenbaum Overview A legal memorandum issued by the IRS (ILM 200645018) has held that the domestic reverse hybrid (DRH) rules apply to deemed payments, and not just actual payments, under a substance over form doctrine. As such, deemed interest payments were treated as constructive dividends.

On March 1 2007, in a preliminary ruling from a VAT Tribunal, the Advocate General's (AG) Opinion was delivered in JP Morgan Fleming Claverhouse Investment Trust plc and The Association of Investment Trust Companies v Commissioners of HM Revenue and Customs (Case C-363/05). The point at issue was the extent of the VAT exemption for management of special investment funds as defined by member states conferred by Article 13B(d)(6) of the Sixth VAT Directive. The exemption provided in VAT Act 1994 (Items 9 and 10 Group 5 VATA 1994) applies to open-ended collective investment schemes such as Authorised Unit Trusts (AUTs) and Open-ended Investment Companies (OEICs), but not to closed entities such as Investment Trust Companies (ITCs). The taxpayer is an ITC which receives management services from a third party which are treated as chargeable to VAT.

Henry An Jin-Young Lee Revisions have been made to several South Korean tax laws. Some of the most significant revisions are:

Monika Dziedzic Poland has signed treaties with Georgia, Iran, New Zealand and the UK. The new agreement with the UK replaces the 1976 treaty.

Lowering taxes to attract investment is not just the preserve of nations. Regional rivalries within federal states can cut an international taxpayer's costs. But as Claire Jones and Catherine Snowdon found out, different regional regimes can also make life a lot trickier

Countries are using tax to compete fiercely for investment. Switzerland should make sure it is not left behind, says Andrin Waldburger of PricewaterhouseCoopers

By Stephen Edge and Gareth Miles of Slaughter and May

By Lars Lawall, PricewaterhouseCoopers

The Bank of China's Hong Kong HQ: tax parity will give more domestic taxpayers the chance to reach the Bank's heights The National People's Congress (NPC), China's legislature, voted today to remove tax breaks for foreign companies.