The Australian Taxation Office (ATO) recently released two tax rulings and a tax determination, providing guidance on
shipping and aircraft leasing profits under the Australian treaties with the U.S. (U.S. DTA) and the UK (UK DTA) in TR 2007/10; payments (in both a treaty and non-treaty context) relative to certain leases of substantial equipment and hire-purchase agreements (TR 2007/11); and application of the Australian treaty with Singapore (Singapore DTA) to certain hire-purchase agreements for substantial equipment (TD 2007/31). Both TR 2007/10 and TD 2007/31 represent a substantial change in the ATO’s position on these issues.

Also in this issue

• France’s published budget acts include changes to R&D and real estate rules
• Austria
  - Tax treatment of outbound transfers of intangibles changed
• Belarus
  - Tax law changes effective for 2008
• Belgium
  - Ruling commission issues guidance on dividends received from Hong Kong
• Brazil
  - Financial transactions tax abolished and other recent changes
• China
  - Transition policies for enterprise income tax issued
• Czech Republic
  -Decree on tax treaty with Mexico issued
• Denmark
  - Government proposes changes to 25 percent tax scheme
• European Union
  - ECJ strikes down Belgian rules on reclassification of interest
• Finland
  - New protocol to U.S. treaty affects individuals
• France
  - Guidance on thin capitalization rules published
• India
  - Computerized reservation system services constitute PE
  - Securities and Exchange Board issues draft REIT regulations
• Indonesia
  - Tax rate for listed companies reduced
• Italy
  - Budget 2008 includes major changes for company taxation
• Japan
  - Proposed 2008 tax reform highlights
• Kuwait
  - Income tax law amended
• Namibia
  - Details of new withholding tax on interest and mining recoupment provisions published
• Norway
  - Transfer pricing documentation rules finalized
• Portugal
  - 2008 budget law includes measures affecting payments to nonresident entities
• United Kingdom
  - House of Lords strikes down three-year cap on input tax claims
  - Application of stamp duty reserve tax on major takeover referred to ECJ
• United States
  - U.S. withholding under newly in force agreements
  - Customs proposes major changes to interpretation of language underlying "first sale" rule
• Venezuela
  - Draft treaty with Malaysia announced
  - Temporary VAT exemption available to small businesses
• Vietnam
  - New personal income tax law passed

Visit the World Tax Advisor Archive for issues from the past six months.

 Subscribe to World Tax Advisor