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The codification of the economic substance doctrine in the US Senate's tax reconciliation legislation may have significant ramifications for bona fide business transactions that are far removed from the tax shelter transactions that are the intended target of the legislation, according to the American Bar Association's Section of Taxation.

The tax reform plan for 2006 was announced on December 19. The plan includes changes in the area of international taxation as follows:

Brian Cowen, the Minister for Finance, set the scene for the Irish Budget when, at a Thanksgiving lunch to the American Chamber of Commerce Ireland, he reiterated the government's commitment to low direct corporate and income taxes as key drivers of economic prosperity in Ireland. This approach was followed in Budget 2006, which was delivered on December 7 and which was very much a "steady as she goes" budget.

According to domestic regulations, contracts wholly or partially involving the transfer, assignment or licence of technology from a foreign party to a local entity, including the provision of technical, financial or advisory services falling under Argentine technology transfer regulations (for example, technical assistance and transfer of know-how), have always been subject to registration requirements with the local technology transfer authorities (National Institute of Industrial Property or INPI) to allow the deduction of the amounts accrued during a given fiscal year.

Taxpayers should be aware that time may still be on their side if they wish to make similar claims to Marks & Spencer. An analysis of other tax cases from the UK courts shows what is possible, explains Simon Whitehead of Dorsey & Whitney

The technical corrections legislation passed at the end of 2005 in the US will have an impact on international tax. Marjorie Rollinson and Michael Mundaca of Ernst & Young explain how this and budget reconciliation, yet to be agreed, will affect taxpayers in 2006

Proposed new section 103 South Africa has a general anti-avoidance rule (GAAR) in the form of section 103(1) of the Income Tax Act No 58 of 1962. In essence, a transaction can be attacked if there are four elements present:

The Mexico-Greece double tax treaty was published on December 31 in the Mexican Official Gazette and became effective from January 1 2006.

The Belgian value-added tax (VAT) legislation foresees in the possibility that invoices are issued by the customer by derogation to the general rule that invoices are to be issued by the supplier of the goods or services (self-billing). In its administrative circular of December 8, the Belgian VAT authorities have now outlined the scope and the application modalities of the self-billing procedure. The administrative circular becomes effective retroactively as from January 1 2004.

China and South-East Asia offers investors a wide range of potential business locations. In the first of two articles, Steven Herring of RSM International examines the tax issues when investing in China, Hong Kong, Indonesia and the Philippines