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  • The European Court of Justice's ruling in the Abbey National case is a key decision for the asset management industry. The reaction of different member states will depend on what investment activities they have considered to be VAT exempt before now, according to Atoz Tax Advisers
  • July 1 sees the start of a significant expansion of the Tax Avoidance Disclosure regime in the UK. Richard Collier-Keywood, of PricewaterhouseCoopers explains what the new regulations aim to capture and comments on whether they are likely to be successful
  • Kevin Rowe of Alston & Bird compares the Alcatel-Lucent merger with the DaimlerChrysler merger of 1998 and assesses how their structuring ensured tax-free status for each merger of "equals"
  • Highlights and photos from the first-ever Asia Tax Executive Forum in Singapore in April
  • Sed Crest speaks to four tax directors from multinationals operating in the region and finds out their staffing secrets
  • The Canadian business community welcomed the new Conservative minority government's first budget, which unveiled several tax benefits.
  • The South African Income Tax Act contains a comprehensive set of provisions relating to the taxation of fringe benefits for employees. Not only are the benefits identified, but the legislation provides for an objective valuation mechanism to determine the quantum of the benefit to be taxed, as well as the reporting and collection mechanisms.
  • The Polish minister of finance has set up the e-taxes project. An amendment to the Polish Tax Ordinance Act, which comes into force as from August 16 2006, introduces an obligation (for some groups of taxpayers) and possibility (for the remaining taxpayers) to communicate with tax authorities electronically. After this date delivering of the tax returns in the electronic version will be compulsory for public bodes, courts, bailiffs and notaries as well as some specific taxpayers such as:
  • The Mexican Senate has recently approved several amendments to the Mexican Federal Tax Code (MFTC), which are pending to be published in the Official Gazette.
  • In some cases, the tax authorities disallow a transaction that companies have legally structured based on the intention of the relevant parties. The tax authorities will argue that the transaction has been conducted purely for the purpose of avoiding tax and reconstruct the transaction from the perspective of economic substance. There have recently been several interesting Japanese court judgments on transactions and their economic substances in international taxation.