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In recent years, eliminating abusive tax schemes has risen to the top of the agenda for revenue authorities, both locally and internationally. Until now individual tax administrations have worked within their own borders to combat revenue evaders but with many tax minimization schemes operating offshore and electronically it is increasingly difficult to track offenders.

The Argentine executive issued Decree No 916/2004 on July 23 2004, which provides clarification and new regulations to the provisions of last year's income tax reform introduced by Law 25.784.

Audit committees are opening up the tax services marketplace to long-overdue efficiencies. Specialists in transaction taxes will notice the change as much as those working in income taxation, according to Richard Thompson Ainsworth of Taxware

The IMF has recommended broadening the US tax base for businesses including a federal sales or value-added tax (VAT) and higher taxes on energy use.

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.

In the Hallminster decision (Case 250328), rendered on February 25 2004, the French Supreme Administrative Court had to decide whether a capital gain realized by a company resident in the UK from the sale of a majority shareholding in a civil company running a vineyard in France was subject to tax in France.

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 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

Alf Capito and Leonid Shaflender of Ernst & Young discuss the recent international tax reforms introduced to increase the attractiveness of using Australia for business and investment