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In a decision dated November 3 2003 (Conseil d'Etat, 244437, SARL Meridia France), the French Administrative Supreme Court had to decide whether the interest paid by a French company to a partner domiciled abroad as current account remuneration may benefit from the withholding tax exemption provided by section 131(4) of the French tax code.

On February 27 2004 the minister of finance released Revised Draft Legislation and Explanatory Notes (the new proposals) that contains significant changes to Canada's foreign affiliate regime. The new proposals revise draft legislation that was originally released on December 20 2002 (the 2002 proposals), and introduce a number of new measures (most not dealing with foreign affiliates), including measures to tax payments for non-compete covenants and measures to allow public corporations to return capital without generating a deemed dividend.

Tax reform in Germany has changed thin capitalization rules and the law on exemptions, among other things. More change is on the way, forecast Eckart Nuernberger and Dirk Pelzer of KPMG

On May 1 2004 EU accession will force 10 new countries to fall into line with EU VAT rules. Simon Briault assesses the progress being made and the impact on multinational business and the EU tax landscape

Senator Helen Coonan, Australia's minister for revenue and assistant treasurer, announced on March 1 2004 that the government will introduce legislation to change the interest withholding tax (IWT) exemptions for payments relating to offshore borrowing.

Michael Hardwick: Tax ruling is part of a trend The European Court of Justice (ECJ) continues to exert a powerful influence on the domestic tax policies of EU member states after a landmark ruling on March 11 2004. The ECJ's ruling in favour of an individual French taxpayer could have wider implications for EU member states that impose company exit taxes.

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In 1998 the IRS and the Treasury Department got the attention of the outbound international tax community by issuing Notice 98-5. The notice sought to challenge certain tax-motivated transactions that generated foreign tax credits (FTCs) by testing their substance under an economic profits test. The transactions described in Notice 98-5 were later included as "listed transactions" subject to the tax shelter disclosure, registration and list maintenance requirements.

Any company considering the adoption of international financial reporting standards (IFRS) will need to consider the tax implications of such a move. In the UK, the main tax area likely to be affected is financial instruments.

On October 13 2003 President Fox issued a decree (the New Decree) that reformed the previous Decree for the Promotion and Operation of the Maquiladora Export Industry (the Decree) issued in 1998. The Decree, which has been amended several times since, granted certain tax and customs benefits to toll-manufacturing companies in Mexico that meet a minimum threshold of exports. The purpose of issuing the New Decree is to provide certainty to companies that have already applied for the Maquila programme and that opted for the benefits granted by the Decree, and for companies that may adhere to it in the future.