As we enter a new year many tax authorities around the globe have been enacting new legislation or publishing fresh proposals. Earnings stripping rules are being proposed in Japan, and there are restrictions on interest deductions related to acquisitions and a surcharge in France. In the US a number of tax reliefs have expired and the Canadian Supreme Court has struck down tax planning using the GAAR. The Indian Supreme Court has held Vodafone was not liable to deduct withholding tax on the purchase price it paid to Hutchison Telecommunications for its Indian assets in 2007.
