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In a vote taken on March 14 2003, which came as no surprise, the Federal Council (Bundesrat) rejected the comprehensive tax Bill introduced by the German government in November 2002. The Tax Preference Reduction Act (Steuer-vergünstigungs-abbau-gesetz or StVergAbG) had cleared the German parliament (Bundestag) by a slim margin in late February. Even after being watered down several times in the course of the legislative process, the legislation still contained important revenue-boosting measures, such as a 50% limit on the offset of the profits of any single year in excess of €100,000 ($108,000) by losses carried forward (net operating losses).

The Australian and New Zealand governments have reached agreement on a solution for the trans-Tasman triangular tax issue. This represents significant progress in addressing a vexing issue that has been on the agenda of both countries for a number of years - and affected businesses will be glad the long wait is over.

French tax authorities have just released administrative guidelines (Official Tax Bulletin, 4 H-1-03, February 26 2003) regarding the inapplicability of a branch tax in France on the profit share due to the foreign partners of a partnership whose head office is in France.

Canadian and foreign multinationals should be aware of proposed amendments to the Canadian foreign affiliate and foreign accrual property income regime. Nick Pantaleo of PricewaterhouseCoopers explains why

The South African Budget announced February 26 introduced tax measures aimed at stimulating business and encouraging investment into the country. One of the most significant measures is the removal of tax on some foreign dividend repatriations. By removing the tax on dividends repatriated into South Africa the government hopes to encourage capital inflows.

The European Commission has launched open consultations on EU company taxation. The first consultation involves using international accounting standards to develop an EU-wide consolidated tax base for companies. The second involves a pilot of the home state taxation scheme for small-and-medium-sized enterprises (SMEs) that would allow an SME to account for EU-wide profits in one tax declaration.

The US Treasury and Internal Revenue Service (IRS) have issued final regulations forcing taxpayers to disclose participation in potentially abusive tax avoidance transactions. The regulations also require promoters to register abusive transactions and advisers to keep lists of clients that have used possibly abusive tax avoidance.

By Bill Archer, former chairman of the House Ways and Means Committee, and Bob Shapiro, former chief of staff of the Congressional Joint Committee on Taxation, PricewaterhouseCoopers

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