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Colombia's new transfer pricing rules set out clearly what is expected of taxpayers, according to Ricardo Rosero, Bernardo Solano, and Fabián Alfonso of BaseFirma

Capital Acquisitions Tax (CAT) is a tax imposed on gifts and inheritances (benefits), which exceed certain tax free thresholds. The recipients of benefits are primarily accountable for the tax. An exemption applies to benefits passing between spouses; all other benefits are taxed at 20%.

The Interest and Royalty Directive of June 3 2003 was amended at the end of April 2004 in the context of the EU accession of 10 new member states. The amendment was necessary because the directive, which provides for abolition of withholding tax on intra Community interest and royalty payments between associated companies, had not yet been adopted when the Accession Treaty was signed in Athens on April 16 2003.

Baker's dozen: the 12 new partners Jesus Alvarado focuses his practice in tax planning and tax consolidation in high tech, telecommunications and entertainment.

The use of Entidad de Tenencia de Valores Extranjeros (ETVE)s by international investors has increased dramatically in the last few years. Both Spanish and non-Spanish newspapers and other publications have reflected this by emphasizing the fact that most large multinationals already have in place an ETVE structure (see the article in Cinco Días, a Spanish economic newspaper, on April 22 2003). More recently, Cinco Días also reported on May 24 2004, that a substantial part of foreign investment coming into Spain in the last few years was made through ETVEs.

In February 2004, the German tax authorities issued a directive addressing the landmark transfer pricing decision rendered by the Federal Tax Court (FTC) on October 17 2001 (see International Tax Review, February 2002, p22). The case involved a German marketing subsidiary of a foreign group; the new directive is limited to this situation. The directive instructs tax officials to disregard key aspects of the October 2001 decision in their future administration of the tax laws.

One of the most basic responsibilities of boards is to balance risk and return so that shareholder value grows and is protected. How then should directors respond to the Taxman elevating tax risk management to the agenda of Australia's top 1500 boards?

During the last decade, large Argentine companies were able to obtain access to medium- and long-term financing at attractive rates through the issuance of corporate securities (Obligaciones Negociables, ONs).

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.