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  • The UK Treasury on September 21 2004 introduced a new package of tax breaks for the film industry, replacing the so-called section 48 incentives. The UK government decided to amend the scheme after a crackdown in February on partnership schemes (often used to fund UK films) that manipulated tax relief to create claims for losses in excess of the capital at risk.
  • By Peter Cussons, international corporate tax partner, PricewaterhouseCoopers, London
  • The German tax practice of US law firm White & Case hired Christoph Schröder, formerly a member of Commerzbank's corporate finance team, on September 15 2004. As a partner at White & Case, Schröder will advise on tax issues relating to capital markets products and company succession planning.
  • Companies seeking tax advice from chartered accountants in New Zealand will get greater privacy after the country's finance ministry announced new rules to level the playing field between accountants and lawyers.
  • The Internal Revenue Service (IRS) and US Treasury Department have issued proposed regulations under IRC section 269B addressing when a stapled foreign corporation will be treated as a US corporation for various purposes (regulation 101282-04). Two or more corporations are treated as stapled entities when more than 50% of the value of the shares of the corporations are subject to restrictions that require their shares to be transferred together.
  • Domestic companies are now subject to thin-capitalization rules in Germany. Taxpayers should examine each structure before deciding whether to take steps to comply with the changes, urge Ralph Dautel, Jochen Murach and Alexander Pupeter of P+P Pöllath + Partners
  • India's Central Board of Direct Taxes (CBDT) has issued an instruction that will benefit Indian and UK taxpayers involved in tax disputes under the two countries' double taxation agreement (DTA).
  • Donald Korb: Handling transfer pricing
  • The European Court of Justice (ECJ) struck out again at national tax systems throughout the EU on September 7 2004, when it ruled that a Finnish man was entitled to a tax credit under Finland's tax system on the dividend he received from a foreign company.
  • The European Commission has adopted a strategy on corporate tax compliance to head off future scandals involving financial malpractice. The strategy, which was released on September 30, calls for actions at the global level to foster company tax transparency and actions at the EU level to strengthen the work of tax administrators and to improve monitoring of companies.