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  • The Ministry of Finance announced a tax reform plan for 2005 on December 19 2004. The plan includes significant changes in the area of international taxation as follows:
  • The government of India has released details of a key value-added tax (VAT) plan that will come into force on April 1 2005. P Chidambaram, the finance minister, said the tax reforms were the most important since India won its independence in 1947.
  • PricewaterhouseCoopers' Chris Rolfe explains what the EU’s code of conduct will mean in practice for transfer pricing disputes
  • The UK Treasury's pre-Budget report pointed towards changes to the tax regime. However, a general election could get in the way of any new initiatives, according to Gary Richards of Berwin Leighton Paisner
  • The US Treasury and the Internal Revenue Service (IRS) have released clarification on the one-time tax break on profit repatriation and the manufacturing deduction in the American Jobs Creation Act (AJCA).
  • A tax partner has left Gleiss Lutz, a German law firm, to set up independently. Wolfgang Blumers took two tax associates, Diethard Goerg and Ulrich-Peter Kinzl, with him to set up the Stuttgart-based boutique Blumers & Partner.
  • In case of Hindustani Powerplus (141 Taxman 658), the Authority for Advance Rulings (AAR) examined the issue of tax implications of allowances and benefits given to expatriates deputed to India.
  • The decision of one of Singapore's leading tax litigators to close his own firm and move to one of the city-state's biggest corporate and financial law firms, is down to the desire of international companies for corporate firms to handle their tax affairs.
  • In December 2004, the EU Council of Ministers agreed on proposals to amend the EC Mergers Directive to improve the relief available to companies operating in Europe. The most important changes to the directive are as follows:
  • The "butterfly reorganization" is the name in Canada for the type of reorganization by which a Canadian corporation, call it the distributor, can distribute property to one or more of its corporate shareholders on a tax-deferred basis. These reorganizations can be done by private corporations or public corporations, and can take the form of a "split-up", whereby one or more shareholders receive their share of the distributor's assets and cease to be shareholders of the distributor, or a "spin-off", whereby the distributor makes a distribution to a new corporation owned by the same shareholders as the distributor and in the same proportion. In 2001, rules were introduced to facilitate spin-offs by public companies. The Department of Finance has now recommended further amendments to the Federal Income Tax Act to provide additional relief for public company spin-offs.