Number 11 - 2006 contains the following:
 

The author considers the aspects of the French anti-abuse tax legislation that have recently been amended to make these rules generally more in line with certain OECD standards and with a view to ensuring compatibility with tax treaties and EC law. The author also analyses recent decisions of the French tax courts that have given rise to significant developments and arguments that could be advanced by taxpayers to counter tax adjustments made by the French tax authorities.

The author first considers the consequences of the co-existence of national tax systems, including the existence of disparities between jurisdictions, the fact that the Member States may treat situations that arise fully within their own jurisdiction differently from those that are partly within and partly without their jurisdiction, and international juridical double taxation. The author then analyses to what extent the Community principles of non-discrimination and non-hindrance prohibit the impediments resulting from the facts that different rules apply in different jurisdictions, that the rules in a single jurisdiction treat internal and cross-border situations differently, and that tax jurisdictions tend to overlap. Finally, the author argues against the concept of "dislocations".

The authors consider tax treaties and Polish domestic law, analyse the significance of Art. 31 to Art. 33 of the Vienna Convention and examine the general relevance of the OECD Model and Commentary, in particular, the importance of referring to domestic law in respect of treaty provisions based on Art. 3(2) of the OECD Model Convention. The relevance of tax and other treaties is then analysed. The authors conclude by examining the significance of Community law for this topic.

This note provides a summary of the 2006 Leiden Alumni Seminar on recent developments regarding case law and tax treaty interpretation and the related discussions.

Details are provided of procedures adopted by Moldova to reduce the rate of social tax and to facilitate the repayment of social tax debts, which are part of Moldova's implementation of balanced economic and tax policies together with the introduction of structural changes.

The author considers the current state of the development of group taxation in Russia and examines the likely changes to be made to Russian tax legislation in respect of this issue.