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The tax authorities have sent the Congress a tax bill including proposed legislation concerning additional interest deductibility restriction to be effected through a series of thin capitalization rules that would enter into force on January 1 2005.

Faced with pressure from the OECD and the EU, many low-tax jurisdictions have fulfilled their outstanding international tax responsibilities. Now they want everyone to know about it. Simon Briault uncovers the changing face of the international tax haven

On September 19 2004, the ruler of Dubai enacted the laws of the Dubai International Financial Centre (DIFC), a recent addition to the several free-trade zones already existing in the UAE. The DIFC aims to benefit the region as a whole by acting as a catalyst for the region's economic development in the same way that similar centres in the US and Hong Kong have contributed to their respective regional development.

Dividends are generally exempt from income tax in the hands of the recipient shareholder in South Africa and there is no withholding tax on dividends. The tax authorities, however, tax dividends in another way, in the form of secondary tax on companies (STC). Subject to a number of exceptions and exemptions, STC is payable by a South African-resident company declaring dividends at the rate of 12.5% of the gross dividend declared. Secondary tax on companies is a direct tax on the company declaring the dividends, although indirectly borne by the shareholders, as they naturally get lower dividends after the STC.

At the heart of discussions within the EU about excessive transfer-pricing documentation requirements being imposed on European multinational enterprises (MNEs), in recent times there has been an increase within the member states of reporting obligations set forth for regulatory purposes, which also include information among related parties.

In the midst of campaigning for re-election, President Bush signed the American Jobs Creation Act on October 22 2004 to end the five-year trade row with the EU over the foreign sales corporation (FSC) and extra-territorial income (ETI) schemes.

Eric Overman, a former member of Deloitte's New York tax practice, has moved to US law firm Pillsbury Winthrop. Overman advises on the tax aspects of asset finance in the manufacturing, mining, telecommunications, real estate and financial services industries. He joined Pillsbury Winthrop's Orange County, California, office on October 10 2004.

The new UK tax disclosure rules, which oblige promoters and in some cases users of tax planning arrangements involving financial products or related to employment to notify details of the arrangements to the Inland Revenue, came into effect on September 30 2004. The notification must include an explanation of each element of the arrangements, its expected tax effect and its legal basis.

The Ministry of National Economy is working on a new income tax law to replace the current legislation, originally issued in 1981. Over the years, amendments have been made to this law through Ministerial Decisions and Royal Decrees. The new law is intended to consolidate the existing legislations, simplify the tax procedures and assist in speedy completion of tax assessments.

Hendrik Blankenstein, formerly international tax counsel for Nestlé, a Swiss food company, started in the Zurich office of Transfer Pricing Associates on November 1 2004. Blankenstein was responsible at Nestlé for issues such as the tax aspects of global acquisitions and supply chain restructuring, for businesses in the Americas and Europe.