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  • The Netherlands has updated its APA rules. Dave Rutges, Eduard Sporken and Kelly Bouman of KPMG Meijburg & Co discuss what this will mean for corporate taxpayers
  • Independence and scope-of-service issues have helped another European law firm to hire tax practitioners from a big-four firm.
  • Recently in Sutron Corporation (268 ITR 156), Indian advance ruling authority (AAR) examined the issue of whether the presence of a country manager in India constitutes a place of business and hence a permanent establishment (PE) of a company. In this case, a US company entered into a contract with the Government of Andhra Pradesh (GAP) in India, under which it was required to supply goods for erecting remote stations and also to provide local materials and services.
  • The recently-released 2004-05 Compliance Program of the Australian Tax Office (ATO) sounded a warning bell for companies, which will face aggressive compliance activity by the ATO in the coming year. While this is not big news for large companies - to which the ATO took their audit stick last year - small-and-medium-sized enterprises (SMEs) should prepare to face harsher scrutiny.
  • The EU's newest members have reacted angrily to criticism from Nicolas Sarkozy, France's finance minister, that their low corporate tax rates are unfair. Sarkozy has claimed that the EU's 10 new members' states low corporate taxes are unfairly drawing jobs and investment away from older EU members.
  • Hungary's favourable tax regime for offshore companies ends in 2005. But the country's tax system will still be attractive to international business, believe Jacques de Servigny and Orsolya Bárdosi of Gide Loyrette Nouel
  • Austria's corporate tax reforms introduce wide-ranging changes, including a tax rate reduction, explain Christian Hoenig and Niklas Schmidt of Wolf Theiss
  • 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.