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David Mayo has Paul, Weiss in New York as a partner in the tax partner. He had previously been a partner of Gibson, Dunn & Crutcher for more than eight years.

Mark Fidelman has joined Ballentine Barbera to open its New York office, where he will be lead partner and principal. He was previously a senior manager in KPMG's New York office.

Adrian Crawford of KPMG explains how recent legislation has increased Ireland's appeal to multinationals seeking a tax-friendly environment

The German thin-capitalization rules include a provision (section 8a (6) KStG – Corporate Income Tax Law) re-characterizing the interest expense associated with intra-group share acquisitions as a constructive dividend if the acquisition is financed using intercompany loans or back-to-back financing arrangements (so-called "tainted loans"). Interest re-characterized as a constructive dividend is effectively non-deductible. However, the provision's broad language leaves many questions unanswered. In particular, the types of acquisitions to which it is applicable are unclear – both with respect to timing and factual situations.

The reinvestment tax refund policy is a well-known tax incentive granted to foreign investors in China where foreign investors may enjoy up to a 100% corporate income tax refund on its direct re-investment in other foreign invested enterprises (FIEs), made with the profits realized from their existing investments in China. Such a policy was firstly launched in 1993 with the obvious intention to encourage foreign direct investment (FDI) into China.

Article 45 section 2 of the Belgian value-added tax code has stipulated for many years that input VAT on cars is restricted to 50%. Only in a very limited number of cases will full VAT deductibility be allowed, for example, for car leasing or car selling.

The Tax Laws Amendment (Loss Recoupment Rules and Other Measures) Act 2005 received Royal Assent on December 14 2005. Australian corporate tax entities which derive foreign income and distribute it directly or indirectly to non-resident shareholders need to consider whether dividends paid on or after December 14 2005 should be declared to be conduit foreign income (CFI) under the newly enacted CFI rules.

Welcome decisions from the Belgian Ruling Commission provide guidance on how to approach transparency for Belgian tax purposes believe Kurt De Haen and Frederique Bearzatto of PricewaterhouseCoopers

Steven Herring of RSM Nelson Wheeler (Thailand) outlines some interesting differences in the tax issues investors face when making a share or asset purchase in Singapore, Thailand, Malaysia and Vietnam

Final withholding tax on interest income introduced The Luxembourg Law of December 23 2005 introduces a final withholding tax on interest income for individuals. According to the law, any Luxembourg paying agent that pays interest to a resident beneficial owner must apply a final withholding tax of 10%. The withholding is final in the sense that no further tax is payable on the income, the interest is not required to be reported in the taxpayer's tax return and it is not taken into account when calculating the average rates of tax on the income.