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  • Roughly a year after the highest German tax court held that Germany's standard transfer-pricing statute could not be applied to an interest-free loan from a German resident shareholder to a German related party, even if the funds were used in a foreign permanent establishment (Federal Tax Court decision of April 28 2005 - I R 5,6/02), the German tax authorities have given notice of refusal to acquiesce in this ruling (directive of July 22 2005).
  • 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.
  • Multinational companies with operations in the United Arab Emirates (UAE) could face higher tax bills after the country asked the IMF to help it to develop a value-added tax (VAT) system.
  • 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.
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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.
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  • New Zealand's 2005 Budget did not fulfil expectations for tax. As a result, the government's tax plan could be the difference between it winning and losing the forthcoming general election, explains Thomas Pippos of Deloitte
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