Global Dispatch, June/July 2008

Belgian companies may utilize excess participation exemption, based on recent ECJ AG opinion -- ECJ: Marks and Spencer principles apply to PEs -- Denmark adopts bill on cross-border hybrid loans, reverse hybrid entities -- Luxembourg to reduce capital duty in 2009, corporate rate reductions coming -- Russia considering tax consolidation regime -- Russian court rules on deducting third-party consulting services -- Spain, Netherlands Antilles sign tax information exchange agreement; NA coming off tax haven list -- Positive Swedish court ruling on exit tax, taxation of tax allocation reserves -- Australia, New Zealand expect new tax treaty in 2008 -- Update on Taiwan’s tax ruling on mergers -- New Brazilian law introduces transfer pricing changes -- Mexico issues annual temporary regulations -- Puerto Rico enacts new tax incentives law effective July 1, 2008 -- US Senate Committee approves Iceland, Bulgaria tax treaties, Canadian protocol