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Patrick Bignon:

The US Treasury Department recently released its detailed tax proposals for the fiscal year beginning October 1 2005. Two of the proposals would affect cross-border transactions.

The main issue in dispute between the taxpayer company, a life assurance company, and the Inland Revenue, was how double tax relief is calculated where the receipt that has been subject to overseas tax is included in trading profits taxed on schedule D-case I principles.

The government released a new anti-fronting law for the UAE in late 2004. It is intended that this law will come into force in 2007 and, should it do so, it is likely to change how business is done in the UAE.

Corporates can expect some far-reaching changes in the tax arena in Spain. Among the initiatives recently announced, which will be embodied in legislative changes in the short term, reference may be made to the approval by the Council of Ministers on February 25 2005 of the first package of measures of the Plan for the Dynamization of the Economy.

Back in 1982 the Supreme Court ruled that a gain realized on conversion of a convertible bond could not be seen as a benefit derived from shares and consequently such gain was not eligible for the participation exemption, even where the holder of the bond already had a qualifying interest in the share capital of the issuer. At the time, this ruling was subject to some criticism, but obviously with no avail to the tax practice.

Interest on loans entered into by a foreign head office and allocated to a Russian permanent establishment (PE) is considered to be sourced from Russia under most double tax treaties (DTTs) concluded by Russia. Therefore such interest is subject to Russian withholding tax (WHT) at the rate of 20%. This rate is reduced to 0% under most DTTs (Russia's treaties with the US, UK, Luxembourg, the Netherlands and Cyprus). However, under certain DTTs (Russia's treaties with Italy and Switzerland), the WHT rate is reduced to 10% or 5% and therefore it is necessary to pay WHT.

Sed Crest discovers how tax directors in North America are dealing with the Sarbanes Oxley Act and why they are less than satisfied with the tax advice they receive

Cole & Partners, a Canadian business valuation and financial litigation firm, has started a transfer-pricing practice with the hire of David Kemp from KPMG. Kemp has 13 years' experience advising multinational enterprises on transfer-pricing planning, documentation and dispute resolution.

The US Treasury's former deputy international tax counsel has moved to private practice after a two-and-a-half-year stint in government.