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  • Gustavo Wunder Andrés Edelstein Ever since the amendment of the personal assets tax law in 2002, foreign investors doing business in Argentina through local companies have been subject to tax on their holdings as of December 31 each year. This is based on the legal assumption without admitting proof to the contrary that the shares and/or participation in the capital of local companies whose owners are companies or other legal entities situated abroad belong indirectly to individuals or undivided estates located abroad.
  • The government used the budget to extend the meaning of India in a bid to increase the tax take, reports Vispi Patel of RSM & CO
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  • The Total Tax Contribution survey is an important addition to the debate on the UK tax system, says Philip Broadley of the Hundred Group
  • By Paolo Giacometti and Raul-Angelo Papotti of Chiomenti Studio Legale
  • By Alvaro Taiar, Alcides Mariano and Ana Luiza Salles Lourenço of PricewaterhouseCoopers Brazil
  • 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.
  • Jordi Dominguez Without taking into consideration the excellent tax framework existing for inbound and outbound investments, one of the most important tax credits provided for taxpayers under the Spanish Corporate Income Tax Act is the tax credit for reinvestment.
  • Henry An Jin-Young Lee Revisions have been made to several South Korean tax laws. Some of the most significant revisions are:
  • Suzanne Boers In 2004, the Netherlands adopted thin capitalisation rules for its national corporate income tax legislation. The Dutch thin cap rules state that interest is not deductible from corporate income if the company's average debt is three times higher than the average equity and this excess is more than €500,000 ($659,000). Furthermore, the amount of interest that is not deductible cannot be higher than the amount of interest paid to related entities, less the amount of interest received from related entities.