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On November 27 2004 the Italian government amended the proposed Finance Act 2005, by inserting significant changes to individual income tax (IRE) and proposing minor changes to the regional tax on productive activities (IRAP). The changes are less extensive of what envisaged by Law 80 of April 7 2003 and, if approved, will be effective as from January 1 2005.

Representative offices remain a popular way of entering the Chinese market. However, their tax treatment differs according to the method used to access them, explain Matthew Murphy, Courtney Macintosh and Kellie Wu, of MMLC Group

Citing Sarbanes-Oxley difficulties, tax partner Philip McCarty has left PricewaterhouseCoopers to rejoin international law firm McDermott Will & Emery (MWE) in Washington, DC, where he worked until 2001.

In a decision that directly affects foreign corporations with US subsidiaries engaged in the solicitation of sales of tangible personal property in the US, the Pennsylvania Supreme Court in Schering-Plough Healthcare Products Sales Corp. v Commonwealth of Pennsylvania, confirmed that Pennsylvania was pre-empted pursuant to Public Law 86-272 (15 U.S.C section 381) from imposing its corporate net income tax on a company whose business activity in Pennsylvania was limited to the solicitation of sales of tangible personal property owned by its parent corporation.

The Canada Revenue Agency (CRA) has issued a series of favourable tax rulings in which it concluded that Canadian domestic anti-avoidance legislation would not apply to certain proposed transactions involving back-to-back cross-border loans. In particular, these rulings consider situations in which Canadian trusts and partnerships use such structures to obtain foreign financing, and in so doing, avail themselves of a withholding tax exemption that is ordinarily only available to Canadian corporations. The favourable outcome of these rulings is good news for both non-resident investors and Canadian non-corporate entities alike.

On September 30 2004 the Brazilian authorities issued Provisional Measure 219 (PM 219), which granted tax benefits on purchases of fixed assets. Effective as from October 1 2004, Brazilian legal entities are allowed to claim a credit for social contribution on net income (CSLL) purposes (to be offset against the CSLL liability), corresponding to 25% calculated over the book depreciation of assets acquired between October 1 2004 and December 31 2005.

Foreign multinationals should examine the recent corporate tax reform carefully for any impact on their US investments, warn PwC advisers in New York and Washington, DC

The Greek government plans to introduce a wide-ranging corporate tax bill that will cut the rate of corporate tax from 35% to 25% by 2007 despite concerns over the country's fiscal deficit. From January 1 2005 there will be tax cuts from 35% to 32% in 2005, falling to 29% in 2006 and 25% in 2007.