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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

Gordon Brown, UK Chancellor of the Exchequer, announced a new tax break for the film industry in his March 17 2004 Budget. The measure will replace the so-called section 48 incentives, which will expire on July 1 2005.

The European Commission announced on March 16 2004 an investigation of the tax incentives offered by the Italian government to newly-listed companies. Upon meeting certain conditions, companies that list their shares on a regulated EU stock exchange qualify as of January 1 2004 to a reduced 20 % corporate income tax rate.

Acombination of previously-announced initiatives and government leaks took the tax sting out of the UK Budget, which was announced by Gordon Brown, the chancellor of the exchequer, on March 17 2004.

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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.

It is common in the US to acquire companies in tax-free stock acquisitions. These are referred to as tax-free reorganizations and they must qualify for tax-free treatment under section 368(a) of the Internal Revenue Code. Section 368(a) provides detailed requirements for several different types of reorganizations (mergers, triangular mergers, stock-for-stock exchanges, spin-offs and certain types of stock-for-asset exchanges for example).

The Spanish CIT law has been reformed for tax years commencing on 2004, to further improve the tax credits for research and development (R&D) and innovation activities.

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.

The increasing complexity and range of tax rules affecting international business require sophisticated and dynamic tax infrastructures in order to deliver global tax objectives. It is for this reason that Ireland is a particularly attractive location for multinationals.