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  • A well-balanced interpretation of anti-avoidance provisions is essential if trust is to be created between taxpayers and tax authorities, according to Marco Da Re and Davide Bergami of Ernst & Young, who analyze some recent cases
  • The new conduit foreign income (CFI) rules (previously released by Treasury as an Exposure Draft in June 2005), are designed to remove an Australian tax liability on foreign sourced income, where that income is ultimately distributed to non-resident investors. They are aimed at improving Australia as an investment choice for foreign investors.
  • The Federal Ministry of Finance brings more legal certainty for investors, argue Florian Schultz and Martina Kästle of Linklaters Oppenhoff & Rädler
  • Fernando Goyco-Covas of Adsuar Muñiz Goyco & Besosa reveals the island's tax benefits, particularly for those serving the US market, as well as exit strategies
  • The Dutch APA team has granted the first royalty advance pricing agreement. Dave Rutges, Eduard Sporken and Jaap Reyneveld of KPMG Meijburg & Co describe how this development helps smaller financial services companies
  • Corporate attitudes to tax risk in the UK have changed significantly over the past two years according to a Deloitte survey of 90 tax directors from FTSE 350 companies.
  • The Supreme Court of Canada has released its decisions on the first cases heard by it involving the general anti-avoidance rule (GAAR) enacted in 1988. The Supreme Court dismissed the Canada Revenue Agency's (CRA) appeal in The Queen vs Canada Trustco Mortgage Co and also dismissed the taxpayers' appeals in Kaulius vs The Queen.
  • On July 1 2005 the Austrian EU Withholding Tax Act (EU-Quellensteuergesetz) came into effect. The Act implements the EU Savings Directive (2003/48/EC).
  • Delegates from around the world debated the latest issues in transfer pricing, including intangibles and allocation of profits, at International Tax Review's fifth annual Global Transfer Pricing Forum in Barcelona at the end of September
  • Baker & McKenzie, an international law firm, has made a series of high-profile appointments, almost doubling the size of its New York tax practice and appointing a former US Treasury tax legislative counsel to its Washington DC office.