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  • Peter Cussons, Juergen Luedicke and Friedrich Roedler of PricewaterhouseCoopers, look at how a common consolidated corporation tax base across Europe might affect business
  • The tax expense allowance for disbursements made to construct and improve public roads The Chilean IRS issued circular letter no 49/2006, regulating the tax treatment of the contributions made by the private sector to the construction or improvement of public roads.
  • Rajendra Nayak Ganesh Pai Apublic interest litigation petition (PIL petition) was recently filed in the Supreme Court of India questioning the powers of the Government of India (GOI) under the Constitution of India (Constitution) to enter into international agreements, including tax treaties with other countries. The petitioner has claimed that the GOI's acts of entering into certain tax treaties and international agreements (including international trade agreements of the World Trade Organization) have violated certain articles of the Constitution and also the fundamental rights granted under the Constitution.
  • Dirk Van Stappen The Belgian Government has drafted a Royal Decree providing for an additional exemption of withholding tax on dividends. It is the intention to extend the existing exemption provided for in the EU Parent-Subsidiary Directive to all countries with which Belgium has concluded a double taxation treaty. The exemption will be subject to the following conditions:
  • Paul Dunne and Jacqueline Seggie of KPMG reveal that many of the proposals in the government's Business Tax Review discussion document seem more about ''business as usual'' rather than real reform
  • Akio Takisaki The new tax treaty between Japan and the UK entered into force on October 12. In Japan, the new treaty will be applicable to the following taxes:
  • Comprehensive reform of global financial structures may be required if capital flight and the resulting tax evasion is to be stopped, believes David Spencer
  • Dieter Endres The finance ministry has issued its long-awaited decree on advance pricing agreements (APA). The ground breaking novelty for the German tax scene is that the authorities seem, for the first time, to be ready to commit themselves in advance on intentions rather than facts. An APA is to be negotiated by the Central Tax Office at the request of the German taxpayer with the competent authority of the other state under the double tax treaty. This overcomes official reticence on tax deals, but does mean that APAs will be bilateral. A multilateral effect is achievable by negotiating the same agreement with each of the relevant national authorities.
  • The UK chancellor's Pre-Budget Report (PBR) has reversed some of the implications of Deutsche Morgan Grenfell's (DMG) victory against the UK authorities, which entitled companies to compensation for corporation tax overpayment.
  • The Ballentine Barbera Group, the transfer pricing unit of CRA International, has set up its first office on the continent of Europe. The firm has hired Gerben Weistra from LECG to be a director in Amsterdam. Weistra's previous experience was with PricewaterhouseCoopers and IntraPrice.