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  • Checking out

    When the OECD advertised its two top jobs in transfer pricing in May, International Tax Review was quick to secure final interviews. Sophie Ashley talks to Mary Bennett and Caroline Silberztein about their reasons for leaving the organisation, what they intend to do next and what they think will happen in their absence.

  • Mary Bennett is homeward bound

  • The show must go on

    Earlier this year Caroline Silberztein announced she was leaving the OECD to become a partner in Baker & McKenzie’s Paris office. In a farewell interview, she discusses her time as head of the transfer pricing unit and how she expects it to progress.


  • US reformers agree on need for lower corporate tax rate

    The US Senate Finance Committee continues to debate and examine the tax code and recent hearings have sought to propose recommendations for reform to the Joint Select Committee on Deficit Reduction, but so far the witnesses are only agreed on one thing: that the corporate tax rate should be lowered. Matthew Gilleard investigates.

  • Effects on ABS notes issued on securitisation transactions

    The Italian government passed Law Decree No. 138 in August, which includes a number of fiscal measures aimed at allowing Italy to balance its budget in 2013, rather than in 2014, by way of reducing expenditures and increasing taxes. Fulvia Astolfi and Maria Cristina Conte of Hogan Lovells analyse the changes with a focus on the tax treatment of asset-backed securities.

  • Ukraine ready to challenge double tax treaty benefits

    Oleg Chayka and Yulia Nogovitsyna of KPMG explain that prospective foreign investors will have to pay more consideration to beneficial ownership requirements and substance when structuring their investments in and transactions with Ukrainian businesses.

  • German tax reporting for foreign limited partnerships

    Many private equity funds, including real estate private equity funds, will not fall under the reporting requirements under the German Investment Tax Act (GITA), but will qualify as limited partnerships under the general reporting requirements of the German General Fiscal Code (GFC), explain Simone Stockmar and Friederike Schmitz of Bödecker Ernst & Partner.

  • Is a UK viable general anti-avoidance rule possible?

    The deadline for the latest review of the feasibility of a general anti-avoidance rule for the UK falls at the end of October. Georgina Colegate-Stone of Exeter College, Oxford takes a fresh look at the arguments for and against in the light of recent cases in the UK and elsewhere.

  • Asia steps up transfer pricing enforcement

    Tax authorities in Asia are releasing more transfer pricing rules and regulations faster than ever before. Understanding this changing landscape will have an impact on tax management in Asia. Penelope Velten of Velten Partners in Singapore unearths the raft of changes across the region and offers advice on how best to respond to what will be likely challenges.

  • Questions raised on the new UK patent box

    Wendy Nicholls and Paul Smith of Grant Thornton UK welcome the new patent box proposals but believe the take-up may be limited because of the restriction to patents (rather than other intellectual property too), the highly complicated calculation of patent box profits, and potentially more favourable regimes within Europe.

  • Unanswered questions after Mayo

    The US Supreme Court’s decision in Mayo earlier this year caught the attention of tax professionals. George Hani and Alan Horowitz of Miller & Chevalier, Washington, DC, argue that the full impact of the case will depend on the outcome of a new case addressing whether deference is owed to a more aggressive effort by the IRS to issue regulations with retroactive effect.

  • Tax planning challenges in Thailand

    Companies looking to invest in Thailand need to think carefully about how they structure their business. With varying tax burdens and different impacts, Chanvitaya Suvarnapunya and Athistha Chitranukroh of DLA Piper run through the options available to taxpayers and offer insight on how to minimise the tax burden.

  • Why environmental tax is topping the political agenda

    Kai Schlegelmilch, vice president of Green Budget Germany/Europe speaks to Jack Grocott about environmental taxation, fiscal reforms and what Europe can learn from Asia’s green tax plans.

  • Are VAT rates reaching their natural peak?

    This time last year, International Tax Review noted a trend in rising VAT rates around the world. Today that trend continues, but opposition is also increasing with calls for cuts in some countries, and new exemptions in others as governments look to stimulate sectors of their ailing economies. Salman Shaheen investigates.

  • How to streamline Spanish real estate investment structures

    The economic and legal situation in Spain has turned some of the structures traditionally used by foreign investors to invest in Spanish real estate into inefficient and highly expensive tools to maintain. Víctor Viana Barral & José Gabriel Martínez Paños of Uría Menéndez outline the disadvantages of these structures and include a proposal for a more efficient alternative.

News Analysis


Tax Relief

  • Tax relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to

International Correspondents

International Correspondents