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PricewaterhouseCoopers indirect tax specialists, Ken Fehily and Ian Jeffrey, look at the goods and services tax and its impact on the Australian tax landscape - and the emerging issues to watch out for

PricewaterhouseCoopers international tax experts, Tony Clemens and Ian Farmer, identify the opportunities and the pitfalls

PricewaterhouseCoopers international tax specialists, Peter Collins and Peter Le Huray, report on the emerging issues in Australia’s thin-capitalization regime including the potential impact of according changes as well as the application of general anti-avoidance rules

The Australian tax and business landscape is a constantly evolving one. Indeed, over the past three years, we have seen the greatest change to taxation in Australia's history

The Italian Tax Authorities issued on June 5 2003 ruling 123/E (the ruling) on VAT (value-added tax) group taxation in case of mergers involving the parent company of the group (the parent company). Company groups are considered differently under Italian law depending on the kind of taxes involved. The following will provide an outline of the current status of the law, as well as the changes that are envisaged in the near future.

The new rules below can be applied to the investment on or after January 1 2003, but from the years ending on or after April 1 2003. If a corporation, whose business yearend is March, acquires the eligible asset during the period from January 1 to March 31 2003, it can enjoy the tax benefits in the year beginning April 1 2003.

Customs and Excise are cracking down on missing trader fraud (where a supplier in a chain of transactions fails to account for VAT and simply disappears), particularly in the computer chip and mobile telephone markets. This may lead to a person who is not involved in the fraud suffering a VAT cost.

The January 2003 issue of International Tax Review reported on the landmark Lankhorst-Hohorst decision of the European Court of Justice (ECJ Case C324/00 of December 12 2002) by which the court held a central provision of the German thin-capitalization rules to contravene EU law.

The Canada Customs and Revenue Agency (CCRA) continues to provide favourable advance income-tax rulings for a common but attractive cross-border financing structure. The structure is used for the financing of a Canadian subsidiary by its US parent. It provides for a tax deduction in Canada and no immediate income inclusion in the US. It also results in a so-called double-dip if the US parent has borrowed the money used to finance the Canadian subsidiary, in particular a deduction of interest expense in both Canada and the United States.

In a decision dated December 30 2002 (Conseil d'Etat, 236096, Hanna), the French Administrative Supreme Court had to interpret article 15 (dividends) of the France-Lebanon Tax Treaty in order to determine whether deemed distributed income as defined by French law was subject to tax in France when paid to a Lebanese resident for tax purposes.