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Changes in the double tax treaty with France

Samantha Nonnenkamp Luxembourg and France have initialled a protocol amending the real estate income provisions of the double tax treaty concluded on April 1 1958.

September 30 2006
A new age in indirect taxation in Romania and Bulgaria

By Daniel Anghel and Malina Marinova of PricewaterhouseCoopers

September 30 2006
New rules on the deductibility of directors' remuneration

Akio Takisaki Under the 2006 tax reforms, the rules on the deductibility of a director's remuneration have changed drastically. According to the revised corporate tax law, the following three types of directors' remuneration can be deducted as expenses of a corporation.

September 30 2006
Withholding tax drops on aircraft leases and tax debt changes

Nélio B Weiss Philippe Jeffrey As discussed in a previous column in this publication, the Brazilian authorities issued on August 3 2006 Provisional Measure 315, which introduced important changes to the foreign exchange legislation. It allowed Brazilian exporters to keep up to 30% of their total export revenues abroad and allowed Brazilian subsidiaries to register in local currency the foreign capital that has not yet been registered with the Brazilian central bank.

September 30 2006
New residence rules for foreign holding companies

Massimo Agostini Pursuant to article 73, paragraph 3 of the Italian Tax Code a company is generally considered to be resident in Italy for income tax purposes if either:

September 30 2006
IRS proposes new foreign tax credit rules

Sean Foley The US Treasury Department and the IRS have proposed significant revisions to the regulations under Internal Revenue Code (IRC) section 901 regarding who is considered to pay a foreign tax for purposes of the US foreign tax credit (see REG 124152-06).

September 30 2006
ECJ backs regional tax regimes in the Azores case

Daniel Armesto In its judgment of September 6 2006, the European Court of Justice (ECJ) has confirmed the European Commission's position with regard to the classification as state aid of the income tax rate approved by the regional Government of Azores, Portugal (C 88/03).

September 30 2006
Investment structures and their tax benefits

By Roberto Carlos Rivas and Mirenchu Muñoz, PricewaterhouseCoopers

September 30 2006
Swiss VAT system and its treatment of leasing as a supply of goods

By Harun Can and Daniel Schafer of Lenz & Staehelin

September 30 2006
Polish VAT law, even after EU accession is still full of gaps

By Tomasz Michalik and Marta Szafarowska, tax adviser of MDDP Michalik Dluska Dziedzic & Partners

September 30 2006

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