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The UK government is maintaining its attack on corporate tax avoidance. It announced a series of changes in February 2005, dealing with controlled-foreign-companies (CFCs) legislation, a limit to the relief claimed for foreign tax paid on trade receipts, the removal of capital redemption bonds' exemption from loan relationships legislation and a ban on buying companies that have incurred losses to avoid tax.

By John Stanhope, Business Coalition for Tax Reform

Private-equity firms, including the Carlyle Group and JPMorgan Partners, have sent a strongly-worded protest letter to the Japanese government about the introduction of a crippling 20% withholding tax on private-equity funds. The tax is expected to come into force from April 1 2005 to close what the authorities say is a loophole in the law.

Gide Loyrette Nouel intends to develop a tax capability in all its offices after the appointment of Anthony Davis as a partner in London. Davis moves from the London office of Cadwalader, Wickersham & Taft, where he was also a partner. He is Gide's first tax partner in London.

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.

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.

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).

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.

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.

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: