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  • The US Internal Revenue Service (IRS) issued updated procedures on July 1 2004 that taxpayers can use to request advance pricing agreements (APAs). The procedures were designed to simplify the process of arranging APAs and to encourage bilateral and multilateral APAs to avoid double taxation.
  • The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty.
  • A Brussels court has just ruled that a dividend of Hong Kong origin is entitled to Belgium's 95% participation exemption, according to Kurt De Haen and Magalie Delattre of PricewaterhouseCoopers
  • 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
  • The number of EU member states increased from 15 to 25 on May 1 this year. In a single move, the opportunities to structure investments for multinational groups in Europe multiplied, according to Götz Wiese and Henrik Lay of Latham & Watkins
  • A test case brought by Debenhams, a UK retailer, could cost Customs & Excise as much as £300 million ($549 million) in lost revenue. The June 29 2004 High Court ruling upheld Debenhams' appeal against an earlier tax tribunal decision that said the company was guilty of avoiding value-added tax (VAT).
  • New legislation aims to encourage private equity and venture capital investment via Luxembourg. Dean Rolfe of PricewaterhouseCoopers discusses the role tax plays in the new vehicle
  • By Jeffrey Owens, director, Centre for Tax Policy and Administration, OECD
  • Directive 76/308/EEC – Mutual assistance for the recovery of customs duties – Application to claims which arose prior to the entry into force of the Directive.
  • Gary Richards of Berwin Leighton Paisner explores the ramifications of the UK's new transfer pricing regime, particularly for foreign groups