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The UK government has dropped Ireland from the list of countries enjoying exemption from the CFC rules. Jason Short and Alistair Craig of Ernst & Young’s International Tax Service Group in London work out why and what it will mean

Switzerland has changed how it taxes derivative financial instruments. As a result, existing rules are further refined and new developments in the financial markets are accounted for. By Andreas Risi, PricewaterhouseCoopers, Zürich

Canada's protocol regime aims to encourage a cooperative relationship between the CCRA and taxpayers and can yield significant benefits. By Hendrik Swaneveld, Martin Przysuski and Venkat Nagarajan, BDO Dunwoody, in Toronto

Dawn Primarolo, UK Paymaster General: businesses should read and respond to consultation Companies in the UK could look forward to a radical overhaul and simplification of the corporate tax system if government plans go ahead. The Treasury, together with the Inland Revenue, has announced that it is launching a consultation process to reform and modernize the tax system. The deadline for industry comment is October 29 2002.

In a July 11 2002 decision (Marks & Spencer Plc v Customs & Excise Commissioners), the European Court of Justice (ECJ) held that the retroactive imposition of a three-year time limit on claims for refund of overpaid value added tax (VAT) was unlawful. The decision is particularly unusual in that it goes beyond the issue that had been referred to the court by the UK Court of Appeal.

The Brazilian tax authorities have for the past few months issued a number of regulations and rulings designed to preserve and/or modify the relevant tax basis. Some recent rulings and rules that are worthwhile to be mentioned are the following.

The Civil Rehabilitation Law (minji saisei-ho) went into effect on April 2000 and replaced the Composition Law (wagi). It outlines the basic restructuring procedures in Japan. By introducing a new legal framework, the main intention was to make it easier for small-and-medium-sized enterprises to take advantage of the provisions.

PricewaterhouseCoopers is the leading tax firm in the UK according to a survey carried out by International Tax Review

Contacts Emails Richard J Wuermli richard.wuermli@taxexpert.ch Christoph Busin christoph.busin@taxexpert.ch Bruno Beer bruno.beer@taxexpert.ch Daniela Fischer daniela.fischer@taxexpert.ch Katharina B Padrutt katharina.padrutt@taxexpert.ch Matthias Erik Vock matthias.vock@taxexpert.ch Löwenstrasse 11

Criticism by the UK government of Ireland's low-tax regime could lead to Irish subsidiaries of UK-owned parent companies facing higher tax bills. The government announced that companies operating in Ireland should no longer qualify for automatic exemption from UK tax. The decision would mean that companies would have to pay the difference between each country's rate of corporate tax. In the UK corporate tax rates can be as high as 30% but in Ireland the rate of corporate tax is 16% and is due to fall to 12.5% from January 2003.