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Acourt in Luxembourg has ruled that capital gains derived by a Luxembourg corporation from the disposal of shares in a French civil company having opted for French corporate income tax do not qualify for the Luxembourg participation regime.

The opportunities of the Dubai commercial environment are becoming increasingly well-known among the multinational business community. One particularly important aspect is the opportunities for tax-efficient restructuring of key business functions in Dubai.

A June 2005 memorandum of understanding has resolved some of the awkwardness in Canada-US mutual agreement procedures. Now the challenge is to put the agreement into practice, says Janice McCart of Blakes Cassels & Graydon

The streamlined sales tax project (SSTP) in the US will come into effect on October 1, after a meeting between state governments on July 1 in Chicago confirmed the project's thresholds will be met.

The national tax administrations have been encouraging taxpayers to obtain advance pricing arrangements (APA) with a notable emphasis on bilateral APAs. This is to ensure the appropriate application of the transfer-pricing rules and regulations, reduce administrative costs relating to transfer-pricing taxation and provide predictability for corporate management. Recently, bilateral APAs processed between Japan and Asia-Pacific countries have been increasing. In 2003 there were 18 cases, which was more than the 16 with the US. On April 28 2005, an amended circular relating to the transfer pricing administrative guidelines was issued noting further clarifications to the APA programme.

Only a few months after the conclusions of Advocate-General Maduro in the "the case of the year" (Marks & Spencer), the full court of the ECJ gave the member states some time to breathe again in the battle between international tax law and EU law. In the D case it decided on the application of the most-favoured nation doctrine to double tax treaties. This decision will be known as one of "these cases" setting the rules of international taxation in the EU.

Court verdicts and new IRS rules have changed the way international tax advisers in the US help their clients, according to Marnin Michaels and Jeffrey Morse of Baker & McKenzie

Following the publication in the Italian Official Gazette of July 4 2005 of the Decree of Ministry of the Economy of June 23 2005, the new tonnage-based corporation tax envisaged by articles from 155 to 161 of the Italian Tax Code (the Tonnage Regime) has become effective - for calendar-year taxpayers - as from January 1 2005.

Martin Zetter, now of LECG, set up and managed the transfer-pricing function for one of the largest financial services multinationals for five years. Here he gives some pointers on getting the most out of an in-house transfer pricing team.

Recently India and Singapore signed the Comprehensive Economic Cooperation Treaty, agreeing to provide various benefits for cross-border transactions in goods, services and investments. As part of this, the existing double tax avoidance treaty between the two countries has also been amended by a protocol. The amendments are effective in India from August 1 2005. Some of the key amendments are: