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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.

Some EU members have conformed with the Interest and Royalties Directive. Others will benefit from transitional arrangements. Philippe de Clippele and Benoit Verschueren of PricewaterhouseCoopers bring us up to date with the state of implementation

The governments of the UK and Gibraltar have challenged a European Commission (EC) finding that Gibraltar's proposed corporate tax reform measures are not compatible with EU state aid rules. The two countries could take their case to the European Court of Justice after the EC declared that Gibraltar's tax system should be the same as the UK's if it is to be regarded as part of the UK for EU purposes.

International tax and beneficial ownership intersect when royalty payments are made cross-border. But there is no consistent definition of beneficial ownership that everyone can use, says Carlos Vargas of KPMG

The special Canary Islands Special Zone (ZEC) tax regime has been in force since 2000 after authorization by the EU authorities. After being in effect for almost four years, this is a good time to weigh up and recall the main advantages and to analyze the level of success and attainment of its objectives.

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

Following the example of other European countries, Italy has adopted a special tax regime for the income deriving from the use of certain vessels, having a net tonnage higher than 100 tons, under the form of so-called tonnage based corporation tax (the Tonnage Regime), pursuant to the new articles from 155 to 161 of the Italian Tax Code (ITC), as amended. More precisely, the Tonnage Regime will enter into force as soon as:

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 Directive establishes no general rule or presumption in favour of one result or the other, but does identify the relevant factors for case-by-case analysis.

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). Under French tax law, individuals receiving interest income from domestic capital investments can opt