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  • Alain Huyghe, Philippe Lion and Herman Huidink of Baker & McKenzie discuss a taxpayer's options in light of anti-abuse provisions in Belgium and the Netherlands
  • Paul Op de Beeck and Eric Warson of KPMG explain some features of Belgium's new tax deduction for shareholder funds or risk capital
  • Keith O'Donnell and Paul Chambers of Atoz Tax Advisers discuss how the legislature and the courts in Luxembourg and elsewhere have influenced international tax recently
  • Companies in the UK with EU tax claims face more onerous procedures after the House of Lords, the UK's highest court, overturned a Court of Appeal decision.
  • By Marienne Shiota Munhoz and Murilo Mello, KPMG Tax Advisers, São Paulo
  • Gary James
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  • The current basis of taxation of dividends received by non-residents in connection with a permanent establishment (PE) in Australia has changed for dividend payments made on or after June 26 2005. These changes have arisen in the amendments contained in the New International Tax Arrangements (Foreign-owned branches and Other Measures) Act 2005 which was given Royal Assent on that date.
  • In two decisions, the Austrian Administrative Court (Verwaltungsgerichtshof) recently qualified the use of foreign base companies as abusive tax avoidance. The Austrian companies, in both cases, channelled interest income – which would be taxable in Austria – into foreign tax exempt or privileged subsidiaries to get such income redistributed to Austria as tax-exempt dividends. According to the court no sufficient reasons other than tax reasons were provided to justify the structure.