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  • Peter Dachs The revised anti tax-avoidance provisions mentioned in last month's publication have been included in the Bill. The surprising aspect is that it appears as if such provisions will be retrospective. In particular, in terms of the Bill, these provisions will apply as from the commencement of years of assessment ending on or after January 1 2007. However it would not be surprising if these provisions were changed so as to ensure there is no element of retrospectivity. If not, affected South African taxpayers will have to analyze their transactions on a retrospective basis to determine whether such transactions complied with the provisions of the new law (which provisions would not have been known to such taxpayers at the time of entering into the transactions).
  • An unexpected verdict on Italy's IRAP tax and a damaging second opinion for the German finance ministry made October a critical month for tax decisions at the European Court of Justice (ECJ).
  • Marina Capel, head of tax of Reuters Asia calls for multilateral improvements to tax administration in Asia
  • No imminent changes to the Internal Revenue Code may be good for the rest of us, believes Chris Wales
  • Rob Withecombe Grant Thornton's management reshuffle in the UK, involving the promotion of Rob Withecombe to head of tax, Ian Evans to a newly created role of global head of tax, and Francesca Lagerberg as a partner to lead the firm's National Tax Office, signals a move to put tax advice at the heart of the practice.
  • Cadbury Schweppes was a UK resident company and the parent company of a group of companies, which included two subsidiaries that were resident in the Republic of Ireland, established in the International Financial Services Centre in Dublin and subject to a rate of tax of 10%. HMRC issued an assessment on the parent company on the basis that the UK's controlled foreign company (CFC) legislation applied. Cadbury appealed arguing that the legislation was contrary to EU law. The case was referred to the European Court of Justice for a preliminary ruling.
  • Tax reform may be needed to abolish taxes that are distorting the economy, report Andrés Edelstein and Gustavo Wunder of PricewaterhouseCoopers
  • Welcome to this Argentina special feature in the November 2006 issue of International Tax Review.
  • Carlos Casanovas, Gustavo Scravaglieri and Ariel Becher of Ernst & Young discuss how the country's thin-capitalization rules affect interest payments to foreign related parties
  • The ECJ has ruled that Italy's regional tax on production is not the same as VAT. Silvia Medici and Luca Dezzani of Dewey Ballantine review the judgment