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The Irish government has continually sought to enhance the attractiveness of Ireland's headquarter and holding company tax regime. The latest offerings can be found in Ireland's Finance Bill 2010 where measures are proposed to improve the regime governing the taxation of inbound and outbound dividends.

Bob van der Made The new EU tax commissioner, Algirdas Semeta presented his work programme to EU finance ministers at the ECOFIN Council on February 16 2010.

Alke Fiebig Tax groups in Germany are conditional on a majority shareholding and on a five-year profit pooling agreement. The latter must meet the formal requirements of tax and company law and must be followed faithfully throughout its term. Deficiencies – both in substance and in formality – give the tax office grounds for re-jecting the agreement and hence the group. Recently, tax auditors – ever in search of revenue – have been keen to exploit this new area.

Phani Tillirou The Cypriot–Russian business affiliations came out stronger from the Federal Arbitration Court after receiving the issued decision last September relating to the unlimited deduction of expenses and more specifically to the unlimited deductibility of interest imposed on loans for corporate profit tax purposes. Russian thin capitalisation rules failed to seal the lawfulness of their applicability against the double tax treaty concluded between the two countries.

Careful study shows that the UK has a lot of advantages as a holding company location, such as favourable withholding tax rules. At the same time, it has its complexities, which also need to be understood, explain Stephen Hales and Alistair Craig of Ernst & Young

The OECD has released a draft implementation package that provides for a streamlined withholding tax relief process. This package is likely to be influential in terms of how countries modernise the cross-border withholding tax relief process. It may result in the holy grail of tax relief at source through standardised documentation and electronic filing to be realised.

The interest for taxpayers in this year's Indian budget came in the proposals to amend existing legislation, such as source rules for non-residents and the tax treatment of a conversion into a limited liability partnership, reveal Vispi Patel and Rajesh Athavale of Vispi T Patel & Associates, Chartered Accountants

A European Court of Justice ruling has tax advisers debating if it diverges from the Marks & Spencer, a key judgment that also tackled whether a subsidiary's losses can be used to offset a parent company's profit in another member state. Esther Martin reports

Enhanced tax information exchange and greater offshore compliance was the biggest outcome of the G20 summit of world leaders last April in London. The subsequent 12 months saw increased tax cooperation between governments and hundreds of international information exchange agreements signed. Jack Grocott discovers what all this means for multinational companies.

By Jack Grocott