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Sixth VAT Directive – Articles 6(2)(a) and 13B(b) – Private use by the taxable person of a dwelling in a building forming, in its entirety, part of the assets of the business – Such use not equivalent to the leasing or letting of immovable property.

Failure of a state to fulfil obligations – Sixth VAT Directive – Article 12(3)(a) and (b) – Supplies of gas and electricity delivered by the public networks – Standing charge for supply networks – Reduced rate.

As from 1994, the year in which the Mexico-US tax treaty (the Treaty) was enacted, it was not clear whether the US limited-liability companies were entitled to the benefits of the Treaty when they were treated as pass-through entities when their partners were US tax residents.

In votes taken on April 11 2003, the German Bundestag (parliament) and Bundesrat (federal council) passed a compromise version of the Tax Preference Reduction Act (Steuervergünstigungsabbaugesetz).

Multinationals doing business in Italy have been confused by recent Supreme Court decisions on permanent establishments, including the Philip Morris case. Piergiorgio Valente and Gianpaolo Valente of Studio Legale Tributario GEB Partners focus new light on blurry concepts

Type of deal

Orrick Herrington & Sutcliffe has opened an office in Milan with 23 lawyers from Ernst & Young's 280-lawyer Italian legal arm, Studio Legale Tributario. The former national director of legal services and anti-trust and regulatory law at Studio Legal Tributario, Alessandro De Nicola, will lead the Milan office. Clients of the lawyers include Italian power company ENEL, Vivendi, Universal Music Italy and Italian insurance company RAS Italia.

For many years the Brazilian government has failed to enact fiscal reforms and to revise its inefficient indirect tax system, which imposes several types of taxes collected by the federal, state and local governments. Over the last decade this situation has developed into a serious tax competition between the different layers of the Brazilian government. The current tax system is characterized as a maze of complicated tax rules, which greatly increase the cost of products and services in the country. The result has been that Brazilian taxpayers are among those with the highest tax burden, representing 36.45% of the country's gross domestic product (only below Sweden - 47% and Germany - 36.7%).

The High Court has overturned the Inland Revenue's position on the tax treatment of share buy-backs. Ian Bowler and Mike Hardwick of Linklaters reveal the implications of the decision

Proposed rules on preferred shares have a lot to offer foreign credit institutions in Spain. Carlos Albiñana of Allen & Overy shows where and how