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For some time, the Chilean domestic law has been promoting the securitisation's activity due to the benefits that this form of financing could generate for the originators as well as for the investors. The mechanisms that encourage and make possible the development of this industry are given from a civil perspective (reduction of paperwork at the assignment; limitations to the defense of the transferred debtor), as well as from a tax perspective.

Nélio Weiss Philippe Jeffrey On December 16 2009, Brazil's executive branch published Provisional Measure (PM) 472 which, among other provisions, introduces thin capitalization rules. Although the PM 472 has entered into force as of December 16 2009, the Brazilian Congress initially had 60 days to veto the provision, modify it, or convert it into law. As the Congress did not act within this initial 60-day period, the PM has been extended for an additional 60-day period.

Nike De Bruyn Herman Driessen In the context of the new VAT rules, applicable from 2010 (the so-called VAT package), the Belgian VAT administration published a new Royal decree (RD n° 57) on March 25 2010 about the place of supply of freight transport services (and ancillary services), which are physically performed outside the EU (for example, a transport of goods from the US to Norway). The aim of this Royal decree is to delocalise the freight transport services, which are performed in a business-to-business (B2B) context, outside the EU if the actual use or exploitation took place in a non-EU country. As a result of this new provision EU VAT no longer applies.

Janne Juusela Tax treaty with India The government has issued a bill (HE 286/2009) enforcing the tax treaty between Finland and India. The primary purpose of the treaty is to avoid international double taxation and to prevent tax avoidance. The treaty was signed in New Delhi in January 15 2010.

Sabine Graziosi In a recent circular letter (AAF nr 4/2010, April 6 2010), the Belgian tax authorities clarified their position on how and when Belgium must grant an exemption for income derived by a Belgian resident in a country with which Belgium has concluded a tax treaty. Note that, for individuals, the exemption is an exemption with progression, meaning that Belgium exempts the income but may, in calculating the amount of tax on the remaining income of that resident, apply the rate of tax which would have been applicable if such income had not been exempted.

Jeffrey Shafer The recent case TD Securities (USA) LLC v HMQ calls into question the Canada Revenue Agency's (CRA) view that a fiscally transparent US LLC is not a "resident" of the US under the Canada-US Income Tax Convention 1980 (the Treaty).

The emergency budget announced by the new British chancellor, George Osborne, will not be delivered until June 22, however, plans have already been unveiled to cut the headline rate of corporation tax.

Foreign investors with representative offices in China need to establish whether they are entitled to a tax exemption under new rules released by the country's tax authorities.

The EU Council reached agreement on Tuesday on a draft regulation to fight VAT fraud, which costs member states billions of euros in lost tax annually.

The Portuguese government has announced that the corporate tax rate for companies whose annual profits are more than €2 million ($2.5 million) will rise to 27.5%