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  • March 2005 was a productive month in tax terms. While the Spanish minister of finance made public the main guidelines for the tax reform announced by the Socialist Party, it was also known that an administrative tribunal ruled on the meaning of the anti-abuse provision relating to dividend distributions to EU parent companies.
  • Last month the Dutch ministry of finance announced a proposal to abolish capital tax from January 1 2006. Capital tax is now levied at a rate of 0.55% on equity contributions to Dutch resident entities with a capital divided into shares.
  • An advocate general opinion of the European Court of Justice (ECJ) exposes inconsistencies between the regional tax on productive activities (IRAP) and the VAT Directive.
  • In recent years Ireland has become an increasingly popular jurisdiction for the establishment of special purpose vehicles (SPVs) for securitization, repackaging, collateralized debt obligations (CDOs), warehousing and other structured finance transactions.
  • The doubt over whether German will renew the double taxation treaty with Brazil has a number of tax implications.
  • The application of the international financial reporting standards (IFRS) in Australia has a number of tax implications.
  • The rules preventing the deductibility of certain costs for subsidiaries outside the EU or EEA do not breach European law, according to an Amsterdam court. Gerben Weening and Samad Laghmouchi of Deloitte explain the decision
  • The US Court of Federal Claims has upheld the taxpayer's claim for a foreign tax credit in the Guardian case. However, the government still has time to appeal the judgment, points-out Ernst & Young
  • Some of the UK Finance Bill's anti-avoidance provisions against international arbitrage and excessive double tax relief transactions are widely targeted and poorly drafted, argue David Haworth and Helen Buchanan of Freshfields Bruckhaus Deringer
  • Sed Crest speaks with Secretary-General Tjaco van den Hout regarding the role of the Permanent Court of Arbitration in The Hague as an alternative way to resolve international tax disputes