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The issue of time limits has come to the fore in tax cases at the European Court of Justice. The court would have to take a number of underlying issues into account before it could depart from existing case law, believes Liesl Fichardt of Dorsey & Whitney

By Stephen Morse and Sarah Norton (UK), Gianni de Robertis (Italy) and Keith Loughman (Ireland)

Taxpayers should not overlook a provision in British tax law that can tax UK shareholders on gains realized by foreign companies, warns Robert Langston of Grant Thornton

Fraudsters committing missing trader intra-community (MTIC) fraud exploit the value-added tax (VAT) rules exempting intra-community sales in the country of dispatch. They acquire the goods free of VAT in one country and then sell them with local VAT in another. However, they do not account for this VAT to the authorities, but pocket it themselves before disappearing. The goods then pass through a chain of further companies known as buffers in a series of transactions legal in themselves and, frequently, are ultimately reacquired by the original seller. At least some of the buffers may be innocent of fraudulent intent, which raises the question – particularly for wholesalers and trading houses of repute – of a VAT risk from buying goods in good faith from dishonest partners.

Legislation has yet to be introduced to give effect to the 2005-06 Australian federal Budget proposal to limit the application to non-residents of Australia's capital gains tax (CGT) rules to real property (whether held directly or indirectly) and the business assets of Australian branches of a non-resident.

The Argentine economy has shown a strong recovery and economists are increasingly optimistic about growth prospects in the near future.

The regional documentation templates that exist are not binding on individual countries. It does not make global documentation rules any more achievable, explains Miles Unwin of Ernst & Young

Jelle Bakker of Bakker Smit Vermeij looks at how draft amendments to the Dutch Corporate Income Tax Act might affect the current tax treatment of hybrid financing instruments. The changes are due to take effect at the beginning of 2007

The nature of international tax means that national revenue agencies and policy makers speak to each other all the time. Groups such as Jitsic (the joint international tax shelter information centre), which brings together the US, the UK, Canada and Australia in an effort against unlawful tax avoidance and the Leeds Castle group of national tax authorities, which as well as the four previously mentioned, includes China, France, Germany, India, Japan and South Korea, discuss best practices in matters such as compliance and administration. National tax authorities also take part in the work of multinational organizations such as the UN, the EU and the OECD.

Judith Harger has become the first tax partner in the London office of LeBoeuf Lamb Greene & Macrae. She joined from Denton Wilde Sapte.