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  • Our international tax team comprises over 50 practitioners throughout Europe. We advise on M&A tax planning, international group structuring, capital markets and banking taxes, employment taxes, real estate taxes, VAT and other indirect taxes, tax investigations and disputes, all as a matter of course. In addition, we have recognised experts in the areas of trusts and private capital tax planning, share incentives and employee benefits and onshore and offshore collective investment schemes.
  • The Polish parliament has accepted some major amendments to the new Value-Added Tax Act, which among other things, changes the rules concerning deduction of input value-added tax (VAT) on purchased and leased cars.
  • A new capital gains tax system on the dispositions of shares or beneficial interests in real estate located in Japan by non-resident individuals or foreign corporations was introduced by the 2005 Japanese Tax Reform.
  • On April 29 2005 the Dutch Ministry of Finance has issued a white paper on the contemplated reform of the Dutch corporate tax system. Subject to the usual legislative process, the envisaged effective date is January 1 2007. In an international context the following highlights are of particular interest.
  • Marks & Spencer (M&S), a UK retailer, invoked articles 43 and 48 of the EC Treaty in an effort to use the losses generated by its subsidiaries in Belgium, Germany and France against its UK profits. In the ordinary course of events, M&S might have used these losses against profits generated by the subsidiaries in the relevant jurisdiction but M&S ceased trading in Belgium, Germany and France, leaving the subsidiaries awash with carry forward losses that were effectively useless or only partially useful.
  • After Israel, the tax treaty with Turkey has recently published and will enter into force on January 1 2006. The treaty is largely based on the OECD model.
  • Italy has implemented Council Directive 2003/48/EC of June 3 2003 on taxation of savings income in the form of interest payments (the Directive) with Legislative Decree of April 18 2005, not yet published in the Italian Official Gazette as of May 16 2005 (the Decree).
  • On April 28 2005 in Brussels the Confédération Fiscale Européenne held a forum entitled Tax Treaty for Europe? During a discussion at this forum the need was reiterated for EU law to take into consideration these international tax principles and not to ignore all the effort that was put into establishing all those principles.