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  • Interpretation of the last sentence of Article 93(3) EC (now Article 88(3) EC) – Prohibition of implementation of proposed measures – Designation of persons who may rely on an infringement – Scope of prohibition when aid consists in exemption from levy – Consequences of final decision for tax previously levied.
  • Article 104(3) of the Rules of Procedure – First and Sixth VAT Directives – Principle of fiscal neutrality – Application of VAT to each production or distribution transaction – Recovery.
  • AMumbai tribunal has held in DCIT v. Reliance Industries Limited (81 TTJ 787) that the charges paid to a foreign company outside India for the hire of ships are not taxable in India.
  • Several EU member states have established attractive holding company regimes. Pat Cullen and Evelyn Forde of Deloitte consider a number of new measures in Ireland's new Finance Bill which will improve its atractiveness in this regard
  • Taxpayers must pay attention to proposals in new transfer pricing regulations, which give the IRS substantial discretion to override the method selected by a taxpayer, argue Ken Wood and David Canale of Ernst & Young
  • The Bush Administration's 2005 Budget proposal and the Treasury's so-called Blue Book (General Explanations of the Administration's Fiscal Year 2005 Revenue Proposals), both published in early February, seek to reform US international tax law in a number of ways.
  • Governments in the Isle of Man and the Channel Islands are moving towards 0% rates of corporate tax in response to EU and OECD pressure on harmful tax practices and to compete with each other for essential foreign direct investment.
  • The Russian State Duma received the draft agreement creating the Unified Economic Territory (UET) on February 16 2004. It brings Russia, Ukraine, Kazakhstan and Belarus together into a free economic zone. Proposed unified customs rules and state regulation procedures would ensure the free circulation of goods, services, capital and labour.
  • UK magic-circle law firm Allen & Overy (A&O) has taken over a top Italian tax boutique to boost its European tax practice in Milan and Rome. Andrea Manganelli and Francesco Parisi, co-founders of Andrea Manganelli e Associati, joined A&O as partners and brought 15 tax associates with them. A&O also hired tax specialist Quirino Imbimbo as of counsel in the Milan office.
  • Bill Ramirez, director of PMI Asia/Pacific taxes, points out some differences between tax practice in Europe and Asia