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In a March 4 2004 decision, the ECJ held that France's taxation of certain types of foreign-source investment income is incompatible with the EC Treaty (case C-334/02, Commission v. France)

Last week Deloitte Touche Tohmatsu, one of the big-four professional services firms, announced that it has separated its tax and legal arm in France, Deloitte & Touche Juridique et Fiscal, in order to comply with French regulations

From July 1 2004 any film from France, Italy, Denmark or Iceland applying for tax relief on the grounds that it is a British co-production must increase the proportion of their budgets spent in the UK from 30% to 40%. The announcement on April 27 2004 is designed to stop so-called co-productions with British filmmakers benefiting from tax relief without providing proportional benefits to the UK economy.

The EU’s member states should devise a common strategy to address the consequences for national tax systems of European Court of Justice decisions in tax cases, according to Philip Gillett, group taxation controller of ICI, the British specialty chemicals and food ingredients group

The US Supreme Court agreed to review the process to resolve large tax disputes after complaints that taxpayers can be hit with multi-million-dollar judgments without knowing how the decision was reached. The April 26 2004 decision relates to cases involving more than $50,000.

Osbourne Clarke, the UK law firm, has secured an alliance with the Milan-based boutique Abbatescianni e Associati that will see the firm’s international tax capability expand further

After a decade of pondering, the German tax authorities have issued a Directive defining their position on the classification of US limited liability companies (LLCs) as corporations or partnerships for German tax purposes (Directive of March 19 2004)

The UK Inland Revenue has announced that it will notify tax advisers when it is about to undertake an employer compliance review of one of their clients

The government released, on March 26 2004, a white paper aiming at improving the direct tax system

In the midst of considerable debate on the potential tax leakage from income fund structures, the Canadian government has introduced several changes affecting pension funds and non-resident investors in Canadian income funds. Income funds are tax-efficient structures that reduce or even eliminate entity-level tax. Investors hold units of a trust and are taxed on distributions from the trust. The 2004 federal Budget dampened the growing enthusiasm for such investments by penalizing certain classes of investors. Pension plans, which represent a significant pool of capital, are now subject to a monthly penalty tax when their investments in business income trusts exceed certain thresholds.