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Spain has brought its thin capitalization rules into line with European Community law. But they still conflict with income tax treaties Spain has concluded with other countries, according to José María Cusí and Norma Peña Bagés of Clifford Chance

Dealing with the compliance burden is only one of the challenges facing tax directors, according to Oliver Bartholet, global head of tax for UBS, the Swiss bank, in this exclusive interview with International Tax Review

Vladimir Putin, Russian President, has targeted the oil industry to pay for sweeping tax reforms that would cut social tax paid by Russian companies. He has said once the tax system is reformed, it must not undergo changes for a long time.

The US has filed a case with the WTO against China, charging that its value-added tax (VAT) rebates for domestic producers of semiconductors violate global trade rules.

The US state of Michigan will give generous tax breaks to General Motors (GM) and Dr. Schneider Automotive Systems, a German car manufacturer, in a bid to retain and create manufacturing jobs. GM will get a $10.4 million single business tax credit over 20 years if it invests $299 million in its Warren transmission plant for future business while Dr. Schneider Automotive Systems will receive a $3.1 million tax credit over 15 years to build a new manufacturing plant.

The Chinese State Administration of Taxation has announced a tax amnesty that will allow foreign residents who are taxable in China to pay their overdue or underreported tax liabilities without penalties. The amnesty allows foreign residents or their withholding agents to remit overdue tax payments on or before June 30 2004, without penalties.

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In the May 2002 issue of International Tax Review (page 58), we reported on a decision by the Cologne Tax Court interpreting language contained in article 23(3) of the former tax treaty between Germany and Canada as a subject-to-tax clause and giving this clause precedence over provisions in the treaty by which items of income "shall be taxable only" in Canada. On appeal, the Federal Tax Court (FTC) has now overruled both the lower court decision and its own 1992 holding on point (judgment of December 17 2003, IR 14/02).