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  • The UK Inland Revenue's interpretation of the decision in the case of Mansworth v Jelley (2003, STC 53) caused much debate last year in the UK as the Inland Revenue surprisingly accepted the decision, even though it was against them, rather than appealing further. Although they subsequently changed their legislation to neutralize the impact of their interpretation of the decision, the ruling could still have an impact in Ireland as the country has similar legislation to that of the UK before this amendment.
  • The introduction of a capital gains tax (CGT) in Hong Kong would be deeply unpopular according to members of the tax community there. Henry Tang, Hong Kong's finance secretary has proposed the introduction of a CGT to increase tax revenues, reduce Hong Kong's spiralling fiscal deficit and broaden the tax base.
  • Kristian Jensen, the Danish minister of taxation, has published draft legislation to tighten the country's transfer- pricing regime. The stringent proposals, intended to comply with the EU principle of freedom of establishment, would introduce documentation requirements for domestic as well as cross-border transactions.
  • From January 1 2005 large companies with operations in Brazil will have to meet monthly instead of quarterly deadlines for filing their federal tax and contributions return. Brazil's Federal Revenue Department, announced on December 2 2004 that companies with annual gross revenues more than BRL80 million ($29 million) will be affected by the changes.
  • By the end of 2004 Germany will have enacted two bills transposing major EU secondary legislation into German law:
  • The JOBS Act has implications for how and when participants in some compensation plans can claim benefits. Companies should be ready to amend their plans, warns Joseph Yaffe of Latham & Watkins
  • A European Court of Justice ruling on value-added tax and investment funds in October 2004 has created opportunities for VAT deductions, reveal Keith O'Donnell and Laurent Grençon of Atoz Tax Advisers
  • The Frankfurt tax practice of German law firm Haarmann Hemmelrath will be strengthened in January 2005 with the arrival of Joachim Krämer and Roderic Pagel, two international tax partners.
  • On October 19 2004 the Swiss Federal Tax Administration published a draft of the guidelines of the agreement between the European Union and Switzerland regarding taxation of savings income in the form of interest payments (commonly known as the Savings Directive).