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  • The Ministry of Finance announced the tax reform plan for 2004 on December 19 2003. The emphasis is on taxing individuals. Corporation tax has not been drastically changed but notable changes are as follows.
  • More than a dozen Bills aiming to reform Germany's labour market, public health insurance system, and tax laws were enacted in December 2003.
  • On October 31 2003 the Brazilian government issued Provisional Measure 135/2003, which, among other things, altered the rules for the application of the social security financing (COFINS) tax. It also introduced new provisions with respect to capital gains realized on the sale of Brazilian assets (including the shares of Brazilian companies) between Brazilian non-residents.
  • One of the first measures announced by the new administration elected in 2003 was a tax reform package mainly intended to combat tax evasion. The government made known its intention to reinforce the punitive legislation on tax crimes and submitted amendments to income tax.
  • The tax treatment of interest payments between related corporate parties and thin capitalization is set to change. Nikolaj Bjørnholm and Steen Halmind of Bech-Bruun Dragsted explain what’s in the proposed legislation
  • 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 on January 29 2004 and brought 15 tax associates with them. A&O also hired Quirino Imbimbo as of counsel in the Milan office.
  • Ecuador’s Supreme Court has ruled that the Canadian oil company EnCana has the right to a partial rebate in its lengthy battle over tax rights with the government, but refuted the company’s claims for a full refund
  • The proposed section 482 services regulations change many aspects of the transfer pricing regulations for related-party services and the ownership of intangible property
  • The law for setting up National Tax Tribunals (NTT) was promulgated recently to dispose of tax cases faster
  • On October 31 2003 the Brazilian government issued Provisional Measure (PM) 135/2003, promoting changes to the COFINS tax regulations