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Bob van der Made Progress on a new proposal by the European Commission for a directive on a common consolidated corporate tax base (CCCTB) now seems highly unlikely in 2009 and even the first half of 2010. The Commission has relieved the head of its CCCTB task force, Thomas Neale, who has become the new head of unit E1: analysis and coordination of tax policies, although Neale also remains as acting head of the CCCTB task force for the time being. The outgoing Commission will be reluctant to take any decisions that are controversial and which could stand in the way of any (re)election bids of Commissioners or any that it feels could be "better dealt with" by a new Commission with a fresh five year mandate.

Stephen Nelson On April 30 2009, the Ministry of Finance (MOF) and the State Administration of Taxation (SAT) finally issued the long-awaited M&A rules pursuant to the enterprise income tax (EIT) law. The new M&A rules are entitled enterprise income tax treatment of reorganisation transactions (Cai Shui [2009] number 59).

Yaniv Lukov A new double tax treaty was signed between Cyprus and the Czech Republic on April 28 2009. The treaty replaces the previous agreement between Cyprus and the former Czechoslovakia. The treaty still needs to be ratified by the Czech and the Cypriot parliament to enter into force.

John Leopardi Emmanuel Sala The Canadian federal and provincial governments levy corporate income taxes. Other than for the provinces of Quebec and Alberta, Canadian provinces have integrated their corporate income tax systems with the Canadian Income Tax Act (ITA).

Nélio Weiss Philippe Jeffrey The tax treaty for the avoidance of double taxation and the prevention of fiscal evasion concluded between Brazil and Russia on November 22 2004 is expected to be effective as of January 1 2010. The treaty, which is mainly based on the OECD model, sets out standard regulations on permanent establishment and business profits issues and limits withholding tax rates on remittances. Yet, article 22 of the tax treaty, which grants taxing rights to the source country with respect to other income, still demonstrates a clear protection of exclusive source-based taxation rights, which is diverging from the OECD model convention.

A report commissioned by the UK prime minister has come down in favour of carbon trading, rather than a carbon tax, as vital in combating climate change.

Dirk Van Stappen The Belgian Ruling Commission continues to play a key role in offering taxpayers and (potential) foreign investors certainty on a wide variety of tax issues. In these turbulent times obtaining certainty on the tax treatment of various aspects of a company's business is a precious asset as it avoids nasty surprises and unexpected cash-outs.

The economic substance doctrine is to be codified under new legislation relating to the restructuring of the US healthcare system.

The European Court of Justice has ruled that Ireland is in breach of European law in relation to how public bodies charge VAT.

Ian Farmer On May 12 the Australian treasurer announced the 2009 budget. This was the first budget for many years that was developed in the context of a domestic economic recession. Australia now faces a A$32.1 billion ($25.5 billion) forecast deficit for 2008-09, compared to the $19.7 billion surplus last year. Real GDP is not forecast to grow again until 2010-11. For the business community, significant proposed changes in the federal budget will see the following tax changes of interest: