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On May 25 2004 the French tax authorities released new administrative guidelines (Instruction 14 B-4-04) concerning the simplification of the procedure US partnerships need to follow to benefit from the French-US tax treaty's reduced withholding tax on French source interest, royalties and dividends.

Section 245 of the Income Tax Act (the Tax Act), enacted in 1988, contains a general anti-avoidance rule (the GAAR) that incorporates a modified business purpose test into Canadian tax legislation. The GAAR will apply if: (1) the taxpayer derives a tax benefit from a transaction or series of transactions, (2) the primary purpose of the transaction or series is to obtain the tax benefit, and (3) the tax benefit results in a misuse of the provisions of the Tax Act or an abuse of the Tax Act having regard to the provisions of the Tax Act read as a whole.

A low tax rate and membership of the EU are part of what makes Cyprus attractive for corporate tax planning, believes Pavlos Aristodemou of Michael Kyprianou & Associates

Charlie McCreevy, the Irish finance minister, has identified the country's tax policy as the key to its economic success in recent years. In a speech on June 24 2004 McCreevy reiterated the government's opposition to French and German calls for greater EU tax harmonization, saying that Ireland remains committed to maintaining its tax sovereignty and its low corporate tax rates.

The French tax authorities use the abuse-of-law theory as an obstacle to oppose tax avoidance schemes when the latter are deemed excessive

The European Court of Justice (ECJ) has ruled against Belgium imposing capital gains tax on the sale of a substantial participation in a Belgian company to a foreign entity. In a preliminary ruling The ECJ found the tax to be incompatible with the EC Treaty.

The Australian parliament has approved changes to the country's controlled foreign corporation (CFC) regime as part of a comprehensive review of the tax system. Regulations published on June 18 2004 will eliminate attribution for most of the income of CFCs (and foreign branches) resident in countries that are taxed comparably to Australia.

The Hong Kong Legislative Council last week passed long-delayed Inland Revenue tax laws designed to crack down on anti-avoidance

After introducing transfer pricing documentation requirements in 2003, the Hungarian government is drafting legislation to introduce advance-pricing agreements (APAs) by 2005

Brazil's House of Representatives' Commission of Finance and Taxation on June 23 2004 approved a law project that extends the time period for filing protests or appeals against federal tax assessments from 30 to 60 days.