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  • The European Commission has approved Ireland's holding company regime, which provides for a tax exemption on chargeable gains arising from the disposal of shares, or assets related to those shares, in some subsidiaries. The regime is part of a package of measures designed to increase Ireland's attractiveness as a holding company location.
  • Peru's tax administration issued a resolution on September 18 2004 establishing new rules for taxpayer registrations in an effort to combat tax fraud. Government tax officials say that many businesses have been issuing false invoices with inaccurate registration numbers and registration numbers that do not exist.
  • George Gillham, a former inspector of taxes with the UK Inland Revenue, joined the law firm Dorsey & Whitney on September 6 2004. Gillham will work with Philip Martin, a high-profile tax litigator and former tax director at the retail company Marks & Spencer.
  • US law firm Greenberg Traurig hired Michelle Ferreira, a former Internal Revenue Service (IRS) litigator, as of counsel on September 8 2004. During her eight-year tenure in the IRS attorney's office Ferreira tried more than 24 cases. She will specialize in estate tax planning at Greenberg Traurig.
  • The recent decision of the European Court of Justice in the Manninen case (C-319/02) has significant implications for the UK's imputation system of dividend taxation.
  • 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. If the acquirer is a foreign company, the capital gain will be (subject to further conditions) taxable in the hands of the vendor. However, if the acquirer is a Belgian company and certain anti-avoidance conditions are satisfied, the capital gain is tax exempt. These rules complicate acquisition structures by the need to interpose a Belgian acquisition vehicle.
  • Adam Craig of Deloitte in London analyzes the potential and progress-to-date of harmonizing corporate taxes in Europe
  • Bringing together the two departments responsible for the administration of direct and indirect taxes has great potential for improving tax administration in the UK, believes Richard Highfield of the OECD
  • The PIS and COFINS taxes have been extended to include the importation of goods and services. Taxpayers need a detailed knowledge of where the new charges apply, warns Roberto Haddad of Branco Consultores
  • Taxpayers must recognize the value of IP and use the correct valuation method for it, believe Weston Anson and Chaitali Ahya of Consor Intellectual Asset Management