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Tax risk management takes in much more now than making sure the figures add up correctly. Angus Johnston of PricewaterhouseCoopers highlights other issues that taxpayers need to be aware of

Article 15 of the Agreement between the European Community and the Swiss Confederation (the Agreement), which set out measures equivalent to those laid down in Council Directive 2003/48/EC, provided for the application of the principles of Council Directive 2003/49/EC on a common system of taxation applicable to interest and royalties, and the principles of the Parent–Subsidiary Directive, to Switzerland. However, regarding Spain, those measures were not applicable until both countries reached a bilateral agreement on the exchange of information.

Talk of reform is in the air in the US and the UK. But what to do and where to start? At an event hosted by International Tax Review and RSM, a distinguished panel of taxpayers, regulators and advisers, along with an invited audience, debated the issues in London in September

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).

The German government has published its plans for real estate investment trusts. The Bill compares favourably to similar structures in other countries, reveals Martin Buenning of Allen & Overy

The rules on preferred tax regimes need to change if local companies are to compete fairly with their international counterparts, believe Fred Barrett of PricewaterhouseCoopers and Timothy Cottrell of CEMEX

The sixth Global Transfer Pricing Forum drew together the world's leading thinkers from governments, multinationals and their advisers for two days in London

Samantha Nonnenkamp Specialized Investment Funds (SIFs) New draft law of specialized investment funds (SIFs) replaces the law on institutional investor funds to introduce more flexibility and extend the concept of eligible investors to professional investors and well-informed investors.

Welcome to the special feature on Italy in the November issue of International Tax Review.

Peter Cussons On September 12, the Grand Chamber of the European Court of Justice handed down its judgment in the Cadbury Schweppes Plc Controlled Foreign Companies (CFC) case. The ECJ has remitted to the UK referring court (the Special Commissioners) the question as to whether the UK motive test can be interpreted so that the UK CFC charge on the UK immediate parent company of an EU (non-UK) lowly taxed (less than 75% of the UK rate ) subsidiary only applies in the case of "wholly artificial arrangements".