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  • In 2003 a Luxembourg-resident company received a tax assessment for the year 1998 from the Luxembourg tax authorities under which the company was denied the right to credit Spanish withholding tax it incurred against Luxembourg municipal business tax (MBT).
  • Treasury and the IRS have promulgated new temporary regulations to allow the making of late purging elections in order to eliminate the passive foreign investment company (PFIC) taint on ownership of shares in certain foreign corporations. This procedure, which requires IRS approval, should help taxpayers who have inadvertently fallen under the PFIC rules.
  • The Minister of Finance presented his Budget speech to parliament on February 15 2006. Apart from announcing changes in tax rates, allowances, exemption thresholds, and the like, the documentation accompanying the Budget speech also spelt out a number of tax-related issues to which attention would be given, and possible amendments to the law to be made.
  • Mark Schofield: Would like more focus on tax risk management Around two-thirds of companies attending a tax risk management seminar in London did not have a written tax risk policy that was signed off by the board.
  • Switzerland is about to make its value added tax system more attractive for businesses, report Mathias Bopp and Michelle Heer of PricewaterhouseCoopers
  • Transfer pricing has traditionally not been an issue for Spanish companies. Under existing legislation the burden of proof lies with the tax administration and there are not specific documentation requirements to be fulfilled by taxpayers.
  • The Norwegian government has withdrawn its appeal to the Norwegian Supreme Court in the Fokus Bank case. Fokus Bank won its case before the Norwegian Appeal Court in May 2005 after the EFTA Court had given its opinion in case E-1/04 of November 23 2004 that the Norwegian withholding tax regime on dividends was conflicting with article 40 of the EEA Agreement (which mirrors article 56 of the EC Treaty).
  • International companies should examine the provisions of the savings tax agreement between the EU and Switzerland to benefit from the reliefs it contains, believe Armin Marti and Anna-Maria Widrig Giallouraki of PricewaterhouseCoopers
  • Switzerland's tax regime has a lot of advantages for any multinational corporation thinking of locating a headquarters there, explain Thierry Sauvaire and Andreas Müller of KPMG
  • By Stephen Edge and Sara Luder, Slaughter and May