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By John Stanhope, Business Coalition for Tax Reform

With Ruling 12/E dated February 1 2005 (the Ruling), the Italian Tax Authorities (ITA) have given their interpretation on the application of the anti-abusive rule set out in articles 110(10) and 110(11) of Presidential Decree 917 of December 22 1986 (the Italian Income Tax Code or ITC), in the context of a commissionaire agreement.

Cristina Arumi and Jonathan Ivinson of Hogan & Hartson analyze the US REIT regime in the context of proposals for similar vehicles in the UK and Germany

Legal privilege protection, the general anti-avoidance provision and permanent establishment under tax treaties featured in some of the more interesting tax litigation in Australia over the past 12 months, reveals Kevin Pose of Allens Arthur Robinson

The panel's brief President Bush set up the bipartisan panel in January with a brief to deliver a report to the secretary of the Treasury with revenue-neutral policy options that:

The US Treasury and the Internal Revenue Service has issued guidance that designates "sale-in/lease-out" or "SILO" arrangements as abusive tax avoidance transactions.

Alan Bell: removed six sectors from income tax net Only an 'economic calamity' would prevent the Isle of Man government from achieving a 0% corporate income tax rate for a majority of businesses in April 2006 as planned, according to the Island's treasury minister. Alan Bell was speaking to International Tax Review in the week after he announced the Island's 2005 Budget in February, which removed six more industries from the income tax net and revealed that the government was negotiating tax information exchange agreements with 10 countries.

Ernst Bunders joined the Isle of Man Treasury as a senior treasury adviser on February 1 2005. He previously worked for the Netherlands government and is an experienced negotiator of tax treaties and agreements.

The UK Treasury has published details of a measure to ensure that researchers are not faced with an income tax and national insurance charge arising on an increase in the value of their shares in a university "spin-out" company due to the transfer of intellectual property.

Nick Gangemi, a former tax partner at Baker & McKenzie, has joined BDO in Australia as national tax technical director. BDO, the international tax and accountancy firm, announced that they had filled the newly-created position in their Sydney office.