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How to price intangibles continues to challenge tax executives in a wide range of industries. Doing so in a way that satisfies tax authorities around the world is a burden, especially as administrators are well aware now of the value of intangibles on company balance sheets. Tax executives need to update themselves regularly on best international practice.

The anti-inversion provisions enacted in 2004 tax legislation are overly broad and may result in significant adverse income tax consequences for many internal restructurings within an affiliated group of corporations, argues Kevin Rowe of Alston & Bird

By Ted Keen, The Ballentine Barbera Group, London and Perry Urken, The Ballentine Barbera Group, Washington, DC

By Alexander Voegele, Stuart Harshbarger and Nihan Mert-Beydilli, NERA Economic Consulting

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).

In October, the German tax authorities issued a form that banks and other unrelated third-party lenders may submit at the request of corporations seeking to avoid Germany's thin-capitalization rules applying to loans they have received.

A condition of China's admission into the WTO was revision of the corporate tax system under which foreign investment enterprises (FIEs) doing business in China are taxed more favourably than domestic enterprises (DEs). The statutory income tax rate applicable to both FIEs and DEs is 33%, however, government statistics reveal that, after taking tax incentives into account, the average effective income tax burden for FIEs is about 15%, as opposed to 25% for DEs. It was recently announced that the tax reforms – an adoption of a unified tax system, which was supposed to come into effect on January 1 2006 – will be delayed.

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.