17 Int'l Tax Rev. 1 (2006)

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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

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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

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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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