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  • The Dutch parliament received a bill proposing the deduction of 3.9 percentage points from the present corporate tax rate on May 24. If passed, the government would implement the deduction in 2007
  • Vivendi, the French media and telecoms company, said it had resolved its dispute with the US Internal Revenue Services (IRS) on June 1. The IRS had wanted $1.5 billion from Vivendi but the company will now only pay $686 million. The dispute was over DuPont shares, which Vivendi acquired when it bought Seagram in 2000
  • László Kovács, the member of the European Commission responsible for taxation, said member states need to make "a more common and coordinated approach at EU level" to combat tax fraud, as he launched a debate to combat the problem. Analysts think that tax fraud costs about €200 billion ($259 billion) to €250 billion in lost revenue, up to 2.5% of the total EU budget. Kovács is particularly concerned about VAT fraud, which alone accounts for about €60 billion. "The Commission proposes a new Community approach to administrative cooperation with third countries and is prepared to engage in a broad discussion on the need to modify VAT systems, " according to the statement launching the debate.
  • Enrique López of Deloitte Abogados y Asesores Tributarios describes how Spain has maintained its attractiveness for cross-border planning
  • Mike Firth and Brian Wurts of PricewaterhouseCoopers discuss how the Goods and Services Tax has performed since it started 15 years ago and how the federal government and the provinces might overcome the obstacles to a national sales tax
  • Under section 18 of the Chilean Tax Code, a company might keep its accounting records in foreign currency as long as it fulfils one of the following:
  • The Brazilian tax authorities issued on March 20 2006 the Interpretation Declaratory Act number 4 (ADI 4) (which is an official interpretation from the Brazilian tax authorities), setting out their understanding in connection with payments of dividends, royalties and technical service fees made under the Brazil-Spain Convention for the Avoidance of Double Taxation ( the tax treaty).
  • In a traditional business model, the legal owner of intangibles is often also the economic owner of the intangibles and remains liable for maintaining or increasing the intangible value. However, the economic and legal ownership of intangible property should not necessarily be situated within a same legal entity.
  • The enlargement and extension of a multinational advance pricing agreement relating to a financial services company demonstrates the flexibility of the concept as a means of providing certainty for taxpayers, according to KPMG
  • A recent Authority for Advance Ruling decision in India relating to Morgan Stanley sought to define the presence of a permanent establishment in the context of the arm's length principle, reports Mukesh Butani of BMR & Associates