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In Argentina non-residents are subject to income tax exclusively on their Argentine-source income. Pursuant to this rule, the non-resident pays tax through a 35% withholding tax levied on a deemed net income equivalent to a percentage of the gross payment received. Unless provided otherwise in the Income Tax Law, 90% of the gross revenue derived by the non-resident from Argentine source is deemed taxable net income, which gives rise to an effective 31.5% withholding tax.

A new study has found that Russian taxpayers want the tax administration to develop a way of dealing with complaints without resorting to litigation.

Popular perception of Arabian Gulf oil-rich states suggests that the region is a high-salary, free-spending and tax-free environment.

Foreign corporate recipients of German-source dividends are often exempt from German dividend withholding tax under the terms of tax treaties and, within the EU, under the Parent-Subsidiary Directive. However, the exemption or a reduced tax treaty withholding rate may be precluded by the anti-abuse provisions of section 50d(3) EStG (German Income Tax Law).

The Chilean Internal Revenue Service, by Ruling 3055 of August 18 2005 repeated its previous opinion with regard to the availability of the use of the value-added tax (VAT) credit originating from the payment of premiums of life insurance and health insurance, contracted by the company in the benefit of its employees.

The Italian government has published Law Decree No 203 in the Italian Official Gazette which has entered into force for all sales of qualifying shareholdings made from October 4. The decree has made a number of changes to the Italian participation regime. The most important of these involve the capital gains participation exemption being reduced from a 100% to a 95% exemption and the minimum holding period being extended from 12 to 18 months.

A case has been brought in a French court questioning the compatibility of article 223A of the French Tax Code with the freedom of establishment. The rule stipulates that a company is not eligible for the tax consolidation regime unless 95% of its shares are held by the parent company.

One of the typical controversial issues in the Spanish tax system has traditionally been tax refunds to non-residents, where the refund is based on tax treaty provisions. This was contentious because under the Spanish General Taxation Law, resident taxpayers are entitled to claim a refund of any taxes incorrectly paid within a four-year period (before 1998, five years), a time limit that applied to non-residents, but only where they did not claim the refund under the provisions of a specific tax treaty (either because they were not resident in a country with which Spain had a tax treaty or because they were not entitled to it). In the latter case, the time limits were traditionally shorter.

Taxpayers in Italy now have another means of achieving certainty in their affairs. Maisto e Associati analyze how the international rulings procedure is to be applied

Arnaldo Salvatore of Macchi di Cellere Gangemi highlights the value-added tax (VAT) issues relating to transactions concerning green certificates