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  • 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
  • Hans Olav Hemnes Several rumours about changes in the tax system flourished before the red-green coalition presented their budget proposal for 2007. The rumours were especially strong regarding changes in the exempt method for dividend and capital gains in limited liability companies, and the possibility for individual shareholders to extract paid-in capital before taxable dividends in limited liability companies. However, the budget proposal contained no fundamental changes in the present tax system, that is, the tax reform introduced from 2004.
  • Neil Wilson The Australian Taxation Office (ATO) has issued Practice Statement Law Administration PS LA 2006/10 setting out the factors that will apply when the Commissioner exercises his discretion to vary foreign resident withholding amounts.
  • International Tax Review's first Americas Awards got off to a strong start in late September. The ceremony was held at the Waldorf Astoria hotel in New York and more than 120 top tax professionals were in attendance to celebrate tax excellence
  • 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
  • Indian ship owners and overseas charterers are unclear about the definition of royalty and use of equipment. The government should step in, believes Ketan Dalal of RSM & Co
  • 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
  • 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).