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Treasury and the IRS have requested information regarding cross-licence agreements (CLA) in connection with an IRS project to provide guidance on the tax consequences of participating in a CLA.

On May 2 2006 the Luxembourg government announced some changes in corporate income tax, income tax, value-added tax (VAT) and social security.

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

The Indian Authority for Advance Ruling (AAR) in the case of Morgan Stanley & Co v DIT recently examined whether a US company had a permanent establishment (PE) in India under the India-USA tax treaty (the treaty) on account of outsourcing certain services to its affiliate subsidiary in India and from deputation of personnel to the subsidiary. The personnel who were to be deputed to India were to be engaged either for providing stewardship services to the Indian company or were to be seconded to work under the control of the Indian company.

The price for refined oil products in China has long remained at a lower level compared to the international market due to China's heavily regulated pricing system. With the international price of crude oil soaring since 2003, the disparity between the price of crude oil and refined oil products in the Chinese market has increased. This could lead to a number of potentially damaging outcomes controlled.

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).

The Australian Taxation Office (ATO) continues to generate rulings and determinations, with regard to the foreign exchange rules (in Division 775 of the Income Tax Assessment Act 1997), which apply from July 1 2003. The highlights of these developments are set out below.

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