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  • As of January 1 2005 the Income Tax Law incorporated new thin-capitalization rules by conditioning the deductibility of interest expense arising from funds received through a loan to a debt to shareholder's equity ratio of 3-to-1.
  • HM Revenue & Customs in the UK has written to the country's top 500 companies to seek the boards' views on a dialogue with the authorities. The new initiative has been launched due to the "desire for greater engagement and discussion with businesses, particularly at board level" according to the HMRC.
  • Almost half of the European and Asia-Pacific tax directors questioned for a global survey have cited transfer pricing as the most important tax issue facing their organizations. Globally, 39% of tax directors identified it as the most important tax issue.
  • Eoin O'Driscoll, president of the American Chamber of Commerce in Ireland, has strongly defended the country´s 12.5% corporation tax rate.
  • The Hungarian parliament has approved a five-year package of tax cuts as part of a government plan to increase competitiveness. The tax package reduces the highest bracket of value added tax from 25 % to 20% and the move will mean a fall in government tax revenue by Ft1 trillion ($4.7 billion) over the next five years.
  • Alexander Lee has been made a tax partner of Paul, Hastings, Janofsky & Walker in its Orange County, California office. His practice concentrates on M&A, dispositions, and recapitalizations of corporations, particularly complex international corporate transactions.
  • The IRS has ruled that section 162(m) of the Internal Revenue Code, on disallowance of deductions for excessive compensation, does not apply to US subsidiaries of publicly held foreign corporations.
  • Under the Spanish Corporate Income Tax Law, Spanish-source dividends received by Spanish resident corporate shareholders who have held, directly or indirectly, at least 5% of the paid-in capital of the company for at least one year, trigger a tax credit amounting to 100% of the tax liability arising from said dividends. In practice, this has the same result as an exemption and fully avoids economic double taxation.
  • 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.