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The following are some of the significant tax proposals recently announced in the Union Budget. These proposals when enacted would be applicable for the tax year 2005/2006.

Brazil has been known for decades to have had strict foreign exchange controls. The government, through the Central Bank of Brazil, has maintained the exchange controls by restricting access to the commercial exchange market to individuals and companies engaged in international trade transactions, repatriation of capital, remittances of dividends, profits, royalties and service fees. Failure to comply with the exchange controls has, as a general rule, precluded the Brazilian payer from making remittances abroad in foreign currency.

Germany's corporate and trade tax consolidation rules were significantly modified in 2003. In February 2005, the tax authorities released proposed administrative guidance on the new rules.

The European Court of Justice (ECJ) held on March 10 2005 that limiting the French tax credit for research expenditure to research carried out in France violates the free movement of services principle of article 59 EC (Case C-39/04 Laboratoires Fournier). Several other EU countries still maintain rules similar to those struck down by the ECJ.

The Tax Amendment Act 2004 (Abgabenänderungsgesetz) has brought about considerable changes in Austria's exit taxation regime. Such changes implement EU legislation on the European Company (SE) and reflect the decision of the European Court of Justice (EU) in the de Lasteyrie du Saillant case (C-9/02).

The Australian Taxation Office's (ATO) concern that multinationals are continually shifting profits has led to increased scrutiny of transfer pricing practices. In particular, the ATO has a renewed focus of the Transfer Pricing Review Project, which deals with:

The fashion among new EU members for a single flat rate for all major taxes gained momentum after Poland's Finance Ministry proposed a flat 18% rate for corporate tax, value-added tax (VAT) and individual income tax.

Mukesh Bhutani: victory bodes well for similar cases Samsung, a Korean electronics company, has won a victory before a Bangalore tax tribunal on the tax implications of shrink-wrap software imports.

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