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  • As previously mentioned in this column in April 2004, the Irish Finance Bill 2004 contained a number of measures aimed at increasing the attractiveness of Ireland as a corporate headquarters and holding company (HoldCo) jurisdiction. Broadly these new measures provided for an exemption from corporation tax on gains arising on the disposal of qualifying shares, and a wider double tax relief for foreign taxes levied on dividends received by an Irish resident company.
  • On September 6 2004 Law 25.924 introduced a transitory regime aimed at promoting investments in industrial activities and infrastructure during the next three years.
  • Taxpayers need to consider several situations when choosing where to locate a holding company in Europe, point out Nick Udal and Allan Cinnamon of BDO Stoy Hayward
  • Leading tax executives, advisers and regulators from around the world came to Berlin in September to discuss the latest issues in transfer pricing
  • Somerset House: Inland Revenue HQ The UK's tax disclosure burden shifted to clients last week after The Law Society reached an agreement with the Inland Revenue on the issue of legal professional privilege (LPP).
  • India's Central Board of Direct Taxes (CBDT) has released a circular to dispel the long-running confusion over the taxation of business process outsourcing (BPO). The September 28 2004 communication confirms that the CBDT will tax BPO units according to the country's transfer-pricing principles and India's extensive tax treaty network.
  • The UK government faces a £3.5 billion ($5.97 billion) bill after the country's Value-Added Tax (VAT) Tribunal referred a mobile phone operators' tax claim on 3G licences to the European Court of Justice (ECJ).
  • Didier Reynders, the Belgian finance minister, has admitted that the results of the tax amnesty he introduced in January 2004 have been disappointing. Reynders was expecting tax revenues of between ?60 million ($76.7 million) and ?70 million ($89.5 million) for the third quarter of the year. But the tax amnesty has so far only yielded an extra ?46.9 million ($59.9 million).
  • Oman's Ministry of National Economy is working on a new income tax law that would consolidate the existing legislation (originally issued in 1981), simplify tax procedures and speed up tax assessments. Interested parties have submitted recommendations on the interpretation of permanent establishments, transfer-pricing rules and the need for an official English version of the tax laws.
  • Hervé Bidaud, an international tax specialist at EY Law, has jumped ship to Fidal in France. Bidaud advises French companies and foreign investors on mergers, acquisitions and reorganizations. In addition to being part of Fidal's tax practice, he will work with Fidal's management to develop international advisory services for mid-market companies.