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Samantha Nonnenkamp As announced by the Luxembourg government following the recent decision of the European Commission on 1929 holding companies, Luxembourg is introducing a new investment vehicle for private wealth investment. A draft law was put before the Luxembourg Parliament on November 20 2006, defining the characteristics and conditions of the Société de Gestion de Patrimoine Familial (or SPF).

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:

Andrés Edelstein Ignacio Rodríguez Argentine government has enacted Law 26,154 which expedites VAT refunds and grants other attractive benefits to the oil and gas sector to encourage the exploration of the nation's hydrocarbons reserves.

DLA Piper's Carlos Rodríguez Barrigüete in Madrid and Eric Ryan and Bernhard von Thaden in California explain how taxpayers should prepare for the new rules

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.

Nélio B Weiss Philippe Jeffrey The presidential election is over and the President Lula's government will remain in power for the next four years for a second mandate. Important tax and social problems remain and will need to be quickly addressed by the government. Some of the main issues that have to be dealt with are; the anticipated reform of the 27 state VAT (ICMS) laws into one federal rule, to reduce the number of applicable ICMS rates from 44 to much fewer, and a reduction of the high tax burden. The task will be onerous, but change is needed to maintain the country as an important player in the worldwide economy and an attractive market for foreign investors.

The increased certainty of an advance pricing arrangement will make them more popular in China, believe Steven Tseng, Julian Hong, Steven Harris and Fred Johnson of KPMG

Samsung, a Korean electronics manufacturer. has appointed a new head of tax for South Asia and plans to add to the team in the coming months.

Sean Foley The Treasury Department and IRS have released new proposed regulations regarding the determination of the income and currency gain or loss of a section 987 qualified business unit (QBU). The intention is to prevent taxpayers from recognizing what are considered to be non-economic foreign exchange losses. The proposed regulations withdraw the existing proposed rules, which were issued on September 25 1991.

Henry An Jin-Young (David) Lee On September 28, the Ministry of Finance & Economy (MOFE) announced comprehensive measures to improve the business environment in Korea. These measures include revisions to rationalise tax regulations.