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  • Brazil reforms cut planning opportunities
  • The UK customs and excise has won a value-added tax (VAT) case in the European Court of Justice, which, had it failed, could have allowed companies to claim back up to £15 billion ($25 billion) in VAT
  • Loyens loses team to Freshfields
  • The importance which Ireland places on double tax agreements is evident from the number to which it is now party. Since the signing of its first agreement on December 31 1951 with the US, Ireland has entered into 35 double tax agreements. Many of these are with Ireland's neighbours, including fellow members of the European Union, however they also include countries further afield such as Japan, Israel, Mexico, Malaysia, South Africa and Pakistan.
  • Sterling profits in Paris
  • Tax measures governing share buyback, capital reduction, and share redemption transactions of Singapore resident companies were recently introduced in Singapore under the Income Tax (Amendment) Act 1999.
  • Central Europe Tax Advice
  • As expected, the European Court of Justice (ECJ) has ruled in the taxpayer's favour in litigation between the French Compagnie de Saint-Gobain SA and the German tax authorities (judgement of September 21 1999 – see our prior report on this case in the December 1997 issue of International Tax Review). The ECJ held that articles 52 and 58 of the EU Treaty (now articles 43 and 48 respectively) were violated by denying tax preferences available to German domestic corporations to the domestic permanent establishment of an EU corporation. At issue were the following preferences:
  • Revenue Canada has finally released its long-awaited transfer pricing circular, detailing its attitudes to legislation put in place two years ago
  • The UK has announced a crackdown on the use of island tax havens, but practitioners doubt the effectiveness of the reforms.