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  • 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)
  • The government of the Netherlands has clarified the rules on how fiscal unities should allocate tax losses to subsidiaries when they leave the group
  • According to the Belgian income tax code, the taxation of capital gains realized by individuals as substantial shareholders on the sale of shares in Belgian companies depends on the residence of the acquirer
  • The recently-released 2004-05 Compliance Program for the Australian Tax Office (ATO) sounded a warning bell for companies, which will face aggressive compliance activity by the ATO in the coming year
  • David Garlick has been appointed as head of the large business service in the UK’s new HM Revenue and Customs (HMRC)
  • The chief counsel of the Internal Revenue Service (IRS) in Washington, DC has disputed findings in a report from Citizens for Tax Justice (CTJ) and the Institute on Taxation and Economic Policy (ITEP) released in September 2004
  • Inter-company aid is the source of much dispute between companies and the French tax authorities, and has, over time, led to the French Supreme Administrative Court, defining a whole set of criteria regarding deductibility
  • Donald Korb, the US Internal Revenue Service (IRS) chief counsel, used his keynote address at International Tax Review’s fourth Global Transfer Pricing Forum in Berlin on September 29 2004 to promote the benefits of the US’ advance pricing agreement (APA) programme
  • 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)
  • By Peter Cussons, international corporate tax partner, PricewaterhouseCoopers, London