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  • The International Financial Reporting Standards (IFRS) came into effect in Australia on January 1 2005. It was clear some time ago that these new accounting standards would impact directly on Australia's thin-capitalization rules, which seek to limit interest expense deductions for certain taxpayers that exceed certain debt-to-asset ratios. This is because the thin-capitalization safe harbour calculation is made with reference to accounts prepared in accordance with Australian accounting standards.
  • Many taxpayers need to change their Dutch conduit entities before December 31 2005 to comply with new Dutch corporate tax legislation, warns Jos Peters of the Rima Marlyn Tax Consultancy.
  • The EU's council of finance ministers (Ecofin) has made progress over differences of opinion on reform of the Stability and Growth Pact, which would reduce budgetary pressure on member states to either reduce spending or increase taxes.
  • Barbara Angus: room for a firm with people of our experience Two senior US government tax officials, Barbara Angus and Gregory Nickerson, have left public service to set up their own tax consultancy firm. Angus & Nickerson opened for business in Washington, DC on February 7 2005.
  • Marks & Spencer's former deputy head of tax, Philip Martin, explains the ramifications if the European Court of Justice sides with the retailer over group relief
  • The US President's Advisory Panel on Federal Tax Reform has its own website at www.taxreformpanel.gov.
  • A transaction in a supply chain in which missing trader fraud is discovered still qualifies as an economic activity for tax purposes, in the opinion of an advocate general of the European Court of Justice. The opinion came in three joined cases of traders, Optigen, Bond House Systems and Fulcrum Trading, against UK Customs & Excise (C-355/03, C-484/03 and C-354/03).
  • Transfers of shares of companies resident in Spain are generally exempt from indirect taxes. In this sense, certain schemes have been tailored in order to avoid Spanish indirect taxes on transfers of real estate properties by transferring shares in companies whose main assets are real estate instead of the real estate itself. In order to block these schemes an anti-abuse provision was introduced in the Spanish transfer tax regulations in 1991, establishing that share transfers could trigger transfer tax at a 6% or 7% rate (depending on the Autonomous Community) provided that:
  • Oman became one of the first countries in the Gulf region to benefit from a ruling from the Supreme Court on the scope of income liable to tax.
  • Mexican entities may now consolidate up to 100% of the taxable income or loss of group members, based on the top Mexican holding company's shareholdings in its Mexican subsidiaries. The increase in the proportion for calculating the participation will have no retroactive effects in connection with the years 1999 to 2004, in which the consolidation was based on the proportion of 60%.