The Minister of Economy declared on 13 March 2008 that the United Arab Emirates is expected to introduce a new company law within 6 months. The new law will allow 100% foreign ownership of companies in some sectors outside free trade zones. Currently, foreign ownership is capped at 49%. Nationals from outside the GCC states must at the moment take a local as a majority partner, except in free zones.

On 31 March 2008, Australia and South Africa signed a new protocol to revise the tax treaty between the two countries dating from 1999. The protocol revises the existing treaty as follows:

· The new Dividends Article provides for a withholding tax rate limit of 5% for all non- portfolio inter-corporate dividends (reduced from 15%).

· The rate remains at 15% for other dividends;

· interest withholding tax remains at 10%, but is reduced to nil where interest is paid to an unrelated financial institution, unless the loan was made under a back-to-back arrangement;

· general royalty withholding tax is reduced from 10% to 5%;

· income derived from equipment leasing (including container leasing) is excluded from the definition of "royalties". Such amounts would either be treated as profits from international transport operations or as business ;

· the tie-breaker residence test for individuals now includes the test referencing residence to the country where the individual is a "national" (the definition of which is also inserted). Where the individual is a national in both, or none of the, States, the treaty provides that the competent authorities of the contracting states shall endeavour to resolve the question by mutual agreement;

· where a temporary resident exemption applies in the source state, the residence state will not give the corresponding relief;

· new Non-Discrimination and Assistance with the Collection of Taxes articles are included;

· the list of taxes covered is expanded

· the scope of the Exchange of Information article is expanded; and

· the definition of a permanent establishment is refined including prescribed time limits for the creation of a permanent establishment where an enterprise operates substantial equipment or is engaged in the exploration for, or exploitation of natural resources.

The protocol will enter into force when both countries advise that they have completed their domestic requirements.

• The Netherlands and Bahrain signed a first-time income tax treaty on 16 April 2008
• Syria and India initialled a new tax treaty on 9 April 2008. Once signed and in force, the new treaty will replace the Syria-India income tax treaty of 6 February 1984
• The first round of negotiations for a first-time tax treaty between Morocco and Saudi Arabia will be held in Rabat on 19-23 May 2008.