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As of January 1 2003, the Mexican tax authorities incorporated into the Mexican Income Tax Law tax incentives for Mexican real-estate trusts (MRET) where the primary activity is the construction or acquisition of real estate for sale or lease. However, some issues remain unclear in the application of the incentives' provisions. In this regard, on May 31 2004, the Mexican tax authorities published some rules in the Administrative Miscellaneous Resolution that clarify some of the issues related to income tax, asset tax (AT) and value-added tax (VAT).

Donald Korb, the new chief counsel of the Internal Revenue Service in Washington, DC, tells Sed Crest what taxpayers need to do to protect themselves and what they should expect from their advisers

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.

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.

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?

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

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).

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