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John Leopardi In the September issue of International Tax Review, my colleagues summarised the Canadian government's recent proposal requiring mandatory disclosure of certain tax avoidance transactions. Quebec is further along in the process, having made several announcements during the last couple of years regarding Quebec's intention to counter aggressive tax planning (ATP), including having released draft legislation and the detailed prescribed reporting form last spring.

Ian Farmer The Australian population voted in a federal election on August 21 2010. At the time of writing, the outcome seems likely to be a hung parliament with the balance of power resting with a number of Independent party and Green party members of parliament. With the two main parties going into the election committing to eliminate the country's deficit but with very different commitments and directions around tax the next few months is likely to be a period of significant uncertainty. In particular, the position of the Independents and Greens is mixed, with some support for measures that were proposed by each of the main parties.

After July's proposal that the Australian government will start taxing resource companies on their profits at a 40% rate, Denise Honey and Leon Mok of Pitcher Partners explain how politics and lobbying forced the government to think twice about this controversial new tax.

Francis Farrell and Charlie Ross of PricewaterhouseCoopers in Ireland outline why international social security is no longer a subject that tax directors should be avoiding.

One month since its introduction, David Gubbay of Dechert explains how the UK's new double taxation treaty passport scheme will increase efficiency for taxpayers, but only if they follow the guidelines.

Alex Cole, Sean Finn & Daniel Friel of Latham & Watkins highlight some of the important differences between various Gulf states, focusing on the GCC, as well as showing how the tax issues facing investors are changing as the region's economic focus expands.

Delegates at International Tax Review's tenth Global Transfer Pricing Forum in Amsterdam last month had many questions and concerns about transfer pricing that ranged from sourcing to financial transactions.

Corporate tax rates around the world have been falling for years and, despite the recession, a number of countries have announced further cuts. Salman Shaheen finds out if the trend is set to continue, or if the race to the bottom is nearing its end

Tax litigation has never been plain sailing. Appeals against revenue authority decisions are increasing and more cases are getting to court. Added to that, the economic downturn means tax authorities are trying to recover as much revenue as they can. But change is happening. Sophie Ashley reports that a lack of government funds is having an effect on litigation tactics as revenue authorities are being forced to become more choosey about which cases to take to court.

Rajendra Nayak Ganesh Pai In the case of Linklaters UK, the Mumbai Income Tax Appellate Tribunal adjudicated on the issue of whether a fiscally transparent entity would be eligible for the benefits under the India-UK tax treaty. Linklaters is a UK-based professional law firm engaged primarily in providing services in the UK. It did not have any business presence in India; however its partners/staff visited India to render services on certain occasions. The eligibility for the treaty benefits is dependent on the taxpayer being regarded as a resident under the treaty. The treaty states that a resident is defined to mean a person who under the laws of a state is liable to tax by reason of his domicile, residence, place of management or any other criteria of similar nature. However, under UK domestic tax law, the taxpayer was treated as a fiscally transparent entity and its partners instead, were taxable on their share of income. The issue before the tribunal was whether the taxpayer having a fiscally transparent status would be eligible for the treaty benefits.