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Diagram 1 Germany put new thin-capitalization rules into effect this year that are intended to conform to the requirements of European law. In July 2004 the German tax authorities released final regulations addressing selected aspects of the new rules.

A recent Indian authority advance ruling (AAR) examined whether a liaison office (LO) of a foreign company constituted a permanent establishment (PE) in India. In this case, a UAE company engaged in the money remittance business had set up a LO in India. It claimed that under the tax treaty business profits are not taxable in India unless they are attributed to an Indian PE. A PE is defined to include any fixed place of business in India through which business is wholly or partly carried on excluding the place maintained solely for the purpose of carrying on any activity of a preparatory or auxiliary nature.

Law 9430 introduced the transfer pricing regime in Brazil on December 27 1996. Under this law, Brazilian taxpayers were allowed to use three different methods to control their import transactions with related parties resident and domiciled abroad:

The changes to the tax arrangements for film investment in Belgium provide significant advantages for both investors and producers, declare Marc Quaghebeur and Ruth De Baere of Vandendijk & Partners

The UK employment-securities rules changed substantially in the Finance Act 2003. The haphazard way they were introduced didn’t help taxpayers to try to understand them, believes Darren Oswick of Simmons & Simmons

India's transfer-pricing regulations place a heavy compliance burden on taxpayers. The tax authorities should make sure that the burden is realistic and equitable, argues Vispi Patel of Deloitte Haskins & Sells

Reserve Bank figures for 2003 The Reserve Bank's figure for 2003 National Bank's pre-tax profit was NZ$439 million ($293 million) with reported tax NZ$143 million ($95 million), whereas the tax paid was NZ$70 million ($47 million).

KIM & CHANG

Dutch telecommunications firm KPN is preparing to file a lawsuit against the Netherlands government for a ?120 million ($146 million) value-added tax (VAT) refund for third-generation mobile phone licenses.

Marc De Munter, formerly a tax specialist with Freshfields Bruckhaus Deringer has joined DLA's Brussels office. De Munter will work alongside Dirk Caestecker and Jeroen Gobbin.