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17 Int'l Tax Rev. 1 (2005-2006)

handle is hein.journals/intaxr17 and id is 1 raw text is: 0 0 Win rst prize in end-of-year quiz! Demonstrate your knowledge in our test on the tax issues that matter Canada Top court interprets anti-avoidance The Supreme Court has provided some valuable guidance on the GAAR, explain David Spiro and Edward Rowe of Blake Cassels & Graydon Netherlands Ruling protects advice privilege A Supreme Court verdict on due diligence reports will benefit taxpayers, believe Hans Seeling and Machiel Visser of PricewaterhouseCoopers France Thin-capitalization reform on the way Taxpayers need to be aware of the changes to thin-capitalization that are due to tax effect from 2007, warns Eric Davoudet of Clifford Chano India Beware the implic'ons of outsourcing IT companies that provide outsourcing to US companies need to be sure of the tax issues, explains Lloyd Pinto of Grant Thornton EU The advantages of a Societas Europaea 84 A number of changes have been made to UK tax law to allow the formation of a European Company, comments Pete Miller of Ernst & Young ~ ~ Ineraioa upaes8 A'sTRALLA * New rules on capital gains tax for non-residents BELGIUM 22 Decree announces tax incentive for productive investments CHILE Changes to the Munidpal Income Law CHINA 24 Unification of the corporate tax code deferred EU The EC's tax caseload overflows GERMANY Tax authorities issue thin-capitalization certification form 29 GULF COOPERATION COUNCIL The application of tax treaties in GCC low-tax jurisdictions MEXICO Decree announces tax incentive for productive investments NETHRLANDS End in sight for dividend withholding tax Norway New govemment proposes loss carry forwards changes RUSSIA Investment requires careful tax planning SOUTH AFRICA 55 Legislation changes tax resident rules SPAIN How Spanish law could be discriminating against EU shareholders S TZERLAND Authorities scrap lump-sum expense deductions 58 UK Court considers reasonable measures to avoid withholding tax on bond issues US INBOUND Why foreign control groups can deduct excess employee compensation 0 0 6 A 0 A A A 00. A 0 A 0 A ~A ~ ~ ~: :. www interns tons.axreview.com Latin America tax services survey 2005 Local tax advisers increase market share Sed Crest finds that directors in Latin America are using more local advisers I 5 Decerber/January 2006 1

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