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The Brazilian tax authorities have been occupied the past few weeks issuing various new regulations. New rules were enacted to provide details and clarify the new requirements for legal foreign entities (and individuals) domiciled outside Brazil to obtain a tax identification number. Likewise, Normative Instruction 208 and Normative Instruction 213 (NI), among others, were enacted on September 27 2002 and October 7 2002, respectively.

A tax treaty signed in early 2002 between Singapore and Romania came into force last week on November 28. The treaty aims to avoid double taxation and prevent tax evasion and will have an effect on all income derived on or after January 1 2003. It also intends to encourage cross-border trade and investment and provides for the exemption or reduction of tax in the source country on various types of income derived by a resident of the other country. This includes tax exemptions on profits from the operations of ships or aircraft in international use and the reduction of source country tax on dividends, interest and royalties.

Foreign exchange and inflation rate fluctuations have a significant impact on the tax position of companies operating in the region. The situation demands innovative tax planning argue Manuel Solano, Terri L Grosselin, and Ricardo Vargas of Ernst & Young

The UK's pre-Budget report introduces some key changes in the way the Inland Revenue determines permanent establishments and how it calculates stamp duty. Gary Richards of Weil Gotshal & Manges works out what it all means for business

Changes to the employee benefit trust scheme announced in the UK pre-budget report could cost London’s financial community hundreds of millions of dollars

The electrical retail group Dixons in the UK fears that a change in the tax regime could cost the company around £20 million ($31.45 million) next year

Luxembourg has threatened to undermine the European Commission’s savings tax directive unless the European Commission forces Switzerland to abandon its banking secrecy

The Russian State Duma (the lower chamber of the Russian Parliament) has recently passed and the Federation Council (the upper chamber) has approved a set of laws ratifying double tax treaties and protocols between Russia and a number of countries, in particular, Austria, Indonesia, Kuwait, Norway, Portugal and Sri Lanka, as well as a new protocol to the double tax treaty between Russia and Finland.

The draft Tax Preferences Reduction Act (Steuervergünstigungsabbaugesetz or StVergAbG), which the German government announced in mid-October, released in early November, and then significantly modified just two weeks later, includes the most important changes in German transfer pricing law since the enactment of the Foreign Transactions Tax Act (Außensteuergesetz or AStG) in 1971. The new measures, passage of which is probable but not certain, represent a legislative response to the Federal Tax Court (Bundesfinanzhof) decision of October 17 2001, which held, among other things, that there is no basis in current German tax law for special transfer price documentation requirements (see articles by Alexander Vögele and William Bader in International Tax Review September 2001 p45 and February 2002 p22). The new rules would apply beginning with fiscal year 2003 (fiscal year 2003/2004 for non-calendar-year taxpayers) and hence take effect almost immediately.

In a recent decision, the Nancy Administrative Appeal Court (April 4 2002, 98-451, SA Maximo) had to decide whether the formation of a holding within the European Union could be regarded as an abuse of law under section L64 of the French Tax Procedure Code.