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A recent case, IndoFood International v J P Morgan Chase, considered what constituted "reasonable measures" in the context of a clause that allowed an issuer of loan notes to redeem those loan notes where an additional tax charge was imposed if the withholding obligation could not be avoided by the issuer taking reasonable measures available to it.

James Fuller, Kenneth Clark, and William Colgin, Jr of Fenwick & West trace the emergence of the IRS' arguments in the Xilinx case, and the role of the new theories on cost sharing in the 2003 final regulations and the 2005 proposed regulations

Transfer pricing has become a key priority in recent years. Decrees are on the way, training for officials has increased and the courts have handed down some important rulings, explain Jobst Wilmanns and Dietmar Kieliszek of PricewaterhouseCoopers

Russian companies are becoming more and more attractive to foreign investors. Attention should be paid to tax structuring when deciding on a potential investment. The validity of this statement can be demonstrated by tax analysis of only one transaction: the purchase of Russian companies' shares from the owner. It may appear that the purchase is a simple and tax-neutral operation for the purchaser. Not in Russia, where the odd logic of the Tax Code may put the purchaser in a bad tax position.

In October the red-green majority coalition replaced the minority centre-right government. The proposals presented below are expected to be passed by the Norwegian parliament (Stortinget).

The GCC states, in their efforts to attract larger volumes of foreign investment, are increasingly willing to enter into and conclude bilateral foreign investment treaties, including bilateral investment treaties, free trade agreements and double taxation agreements. Of particular interest and some debate is the application of tax treaties in the low-tax jurisdictions of Bahrain and the UAE. Bahrain's tax laws only apply to the profits of oil companies, while, within the UAE, although general taxing provisions apply to all businesses, in practice only the profits of oil companies are taxed.

Investment partnerships or professional partnerships that do not register the domicile of their domicile will have to pay the municipal tax in the district corresponding to the domicile recorded before the IRS.

The 2005 Australian federal Budget contained proposals to restrict the range of assets that will be subject to Australian capital gains tax (CGT) in the hands of non-residents.

Pete Miller of Ernst & Young argues that the European Company, Societas Europaea or SE, that is part of the EU Mergers Directive, is part of what is probably a move towards greater harmonization of company law and regulation throughout the EU

Tax practitioners' reports for their clients in the Netherlands have been further protected by a Dutch Supreme Court ruling. Hans Seeling and Machiel Visser of PricewaterhouseCoopers compare the judgement to practice in other jurisdictions